A Review of the Liechtenstein GloBE Regulation

On March 28, 2024, the Decree on the minimum taxation of large groups of undertakings (the ‘GloBE Regulation’) was published in the Official Gazette.  This follows the Minimum Tax Act (to implement the GloBE Rules), which was published in the Official Gazette of Liechtenstein on December 22, 2023.

The GloBE Regulation provides additional detail on:

– the GloBE Commentary and the Administrative Guidelines for the interpretation of the GloBE Model Regulations;

– the Transitional CbCR Safe Harbour;

– the recognition of foreign top-up taxes;

– the tax return for the levying of the Liechtenstein domestic minimum tax and the IIR top-up tax;

– the GloBE top-up tax return.

The GloBE Regulation is relatively brief but this is to be expected as Liechtenstein has implemented the OECD Model Rules directly into domestic law via a static reference. Nevertheless, the GloBE regulation is important, not least as it specifically implements Safe Harbours and the OECD Administrative Guidance into domestic law.