Liechtenstein Issues Pillar 2 Registration Rules

Registration

On January 9, 2025, Liechtenstein released its GloBE Registration form. This follows amendments made to Liechtenstein’s GloBE Regulation by Ordinance 2024/456 , published in the Official Gazette on December 13, 2024. Liechtenstein’s updated GloBE Regulation can be viewed at: Updated GloBE Regulation. 

Article 5(3) of the GloBE Regulation (as inserted by the December 2024 amended GloBE Regulation) provides that domestic constituent entities of an in-scope MNE or domestic group (including excluded entities) must submit a registration notification to the tax administration within 6 months after the end of the financial year the group has entered the scope of the GloBE rules in Liechtenstein. This applies to fiscal years starting on or after January 1, 2024.

The GloBE registration form is required to be submitted via email to the Tax Authority and requires the following details:

-Name of the Constituent Entity located in Liechtenstein

-Tax Identification Number of the Constituent Entity located in Liechtenstein

-Type of Constituent Entity located in Liechtenstein (UPE, MOPE, POPE, CE or  excluded entity)

-Name and address of the Ultimate Parent Entity 

-Name and address of the Constituent Entity which will submit a tax return for the collection of the Liechtenstein DMTT 

-Name and address of the Constituent Entity to which the Liechtenstein DMTT is to be allocated and from which it is to be collected (either due to a domestic constituent entity being designated for DMTT collection or under the default allocation rules under Article 6 of the Minimum Tax Act).

-Name and address of the Constituent Entity which will submit a tax return for the collection of the IIR top‐up tax

-Name and address of the Constituent Entity which will submit a GloBE Information Return for the collection of the IIR top‐up tax 

Filing Returns

Article 13 of the Minimum Tax Act provides that the following returns are required to be submitted:

• A QDMTT return

• A GloBE top-up tax return (IIR)

• A GloBE Information Return (GIR)

However, Article 5(1) of the GloBE Regulation provides that a combined return for the QDMTT and IIR will be submitted.

Article 5(2) of the GloBE Regulation (as amended by the December 2024 amended GloBE Regulation) states that this must be submitted within 12 months from the end of the financial year. The tax administration can extend the submission deadline upon a reasoned written request.

The GloBE Regulation does not provide significant additional detail and states that the QDMTT return/GloBE top-up tax return is to be submitted in accordance with the requirements of the tax administration. The attachments to the tax return and the other documents to be submitted must be submitted in German or English.

Article 6 of the GloBE Regulation covers the GIR. The standard filing deadlines apply (15 months of the end of the financial year/18 months in the transition year). Unlike the GloBE top-up tax returns there is no filing extension available.