| Status | Enacted Law |
| Law | On March 18, 2025, the government approved a draft bill on the amendment of Liechtenstein’s Global Minimum Tax Act. The bill is intended to implement domestically the OECD provisions for the exchange of information in the GloBE Information Return (GIR) under the Multilateral Competent Authority Agreement on the Exchange of GloBE Information. On March 28, 2024, the Decree on the minimum taxation of large groups of undertakings (the ‘GloBE Regulation’) was published in the Official Gazette. On December 13, 2024, an Ordinance was published in the Official Gazette to amend the GloBE Regulation. On December 22, 2023, the Minimum Tax Act (to implement the GloBE Rules), was published in the Official Gazette of Liechtenstein, No. 2023/484. |
| Effective Date | January 1, 2024. |
| IIR | Yes (2024) |
| UTPR | Yes (2025) |
| QDMTT | Yes (2024) |
| Filing Deadlines | Yes – Standard |
| Safe Harbours | Yes – all |
On March 18, 2025, the government approved a draft bill on the amendment of Liechtenstein’s Global Minimum Tax Act. The bill is intended to implement domestically the OECD provisions for the exchange of information in the GloBE Information Return (GIR) under the Multilateral Competent Authority Agreement on the Exchange of GloBE Information. This was approved by Parliament on November 5, 2025.
On December 13, 2024, an Ordinance was published in the Official Gazette to amend the 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.
On December 22, 2023, the Minimum Tax Act (to implement the GloBE Rules), was published in the Official Gazette of Liechtenstein, No. 2023/484.
On March 29, 2023, Liechtenstein published draft legislation for the implementation of the Pillar Two Globe Rules.
GLOBE APPLICATION
General
The Minimum Tax Act provides for:
-an Income Inclusion Rule (IIR);
-an Under-Taxed Payments Rule (UTPR); and
-a Qualified Domestic Minimum Top-Up Tax (QDMTT).
The IIR and QDMTT are to apply to in-scope MNE groups for accounting periods beginning on or after January 1, 2024. The UTPR is to apply to accounting periods beginning on or after January 1, 2025.
Liechtenstein takes a similar approach to Switzerland, with Article 2(1) of the Minimum Tax Act providing that the GloBE Model Rules are directly applicable. The Minimum Tax Act therefore transposes the OECD Model Rules directly into domestic law via a static reference.
The GloBE Model Rules are defined as ‘…the “Global Anti-Base Erosion Rules (Pillar Two)” approved on December 14, 2021 by the Inclusive Framework of the OECD and the G20…’.
There is therefore no automatic transposition into domestic law of any changes to the OECD Model Rules. This is confirmed in the Treasury’s Commentary to Article 2 of the Minimum Tax Act which specifically states that the transposition of the OECD Model Rules is via a static reference.
Article 2(2) of the Minimum Tax Act provides that the model rules are to be read so that Liechtenstein is the implementing jurisdiction wherever there is placeholder text.
Given the standard corporate income tax rate in Liechtenstein is 12.5% (under Article 61 of the Law on State and Municipal Taxes), domestic entities/PEs of foreign MNE groups and large domestic groups are likely to be subject to top-up tax (unless there are significant differences between domestic and GloBE treatment).
Administrative Guidance
The Commentary on the Model Rules, Safe Harbours Guidance, the Administrative Guidance and other relevant OECD guidance are not specifically transposed in the Minimum Tax Act. However, the Commentary to the Minimum Tax Act states that in order for these to be legally binding in Liechtenstein an Ordinance to accompany the GloBE Law is to make them directly applicable.
Article 2 of the GloBE Regulation specifically provides that the GloBE model regulations, which are implemented into domestic law in Article 2(1) of the GloBE Act) are to be interpreted in accordance with:
-the GloBE Commentary (“Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two)”; and
-the Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two)
This will therefore ensure that all amendments and clarifications in the OECD Administrative Guidance (three sets issued to date) are implemented in Liechtenstein.
Safe Harbour and Penalty Relief Guidance
Article 28 of the Minimum Tax Act does specifically apply the Transitional CbCR Safe Harbour.
Further detail is provided in Article 3 of the GloBE Regulation, which provides that the GloBE calculation may be simplified in accordance with the following provisions contained in the Safe Harbours and Penalty Relief: Global Anti-Base Erosion Rules:
-Transitional CbCR Safe Harbour arrangements; and
-Permanent Safe Harbour arrangements.
The Transitional CbCR Safe Harbour only applies to tax years beginning on or before 31 December 2026; they do not apply to tax years ending after 30 June 2028.
This should therefore ensure that that the Transitional CbCR Safe Harbour and the Permanent Safe Harbour (currently for Non-Material Constituent Entities) applies in Liechtenstein.
The other Safe Harbours (Transitional UTPR and QDMTT Safe Harbours) should apply as the OECD Administrative Guidance is now implemented in Article 2 of the GloBE Regulation.
ELECTIONS
Elections in the OECD Model Rules
As the Minimum Tax Act transposes the OECD Model Rules into domestic law, all relevant elections in the OECD Model Rules will also apply in Liechtenstein.
Elections in the Administrative Guidance
As the GloBE Regulation transposes the provisions of the OECD Administrative Guidance into domestic law, all relevant elections in the OECD Administrative Guidance will also apply in Liechtenstein.
DEVIATIONS FROM THE OECD MODEL RULES/EU GLOBAL MINIMUM TAX DIRECTIVE
Given the GloBE rules are directly transposed into domestic law, the Minimum Tax Act is relatively high-level. The GloBE Model Rules are regarded as domestic law. Therefore, there are minimal differences to the model rules.
The only differences arise from the fact that as a member of the EEA, large domestic groups are also be included in the scope of the GloBE Rules.
Article 9 of the Minimum Tax Act provides that the UTPR is to be applied as a separate tax charge (as opposed to a denial of a deduction or other notional income).
DOMESTIC MINIMUM TAX
General
The Minimum Tax Act specifically provides for a Liechtenstein domestic minimum tax. Article 4(1) provides that the Liechtenstein domestic minimum tax is a QDMTT as defined in Art 10.1.1 of the OECD Model Rules. Given there is more leeway given to jurisdictions over the design of their QDMTT, there are a number of specific provisions in the Minimum Tax Act that impact on the QDMTT.
QDMTT Design Features
Liechtenstein takes a similar approach to Germany in that it bases the QDMTT on the general top-up tax calculation, and then subjects it to a number of adjustments. This is unlike, for example, the UK which has a detailed, standalone QDMTT.
Article 4(3) provides that if in the tax jurisdiction of an ultimate parent entity a threshold lower than 750 million euros applies for the application of the GloBE Rules, domestic group entities are to be subject to a QDMTT (in order to retain Liechtenstein’s taxing right). The 2025 Amendment Bill proposes to repeal this provision.
Article 5 includes a number of amendments to the application of the QDMTT. Article specifically applies a provision of the OECD Administrative Guidance which states the QDMTT is not reduced in the case of entities not wholly owned (unlike the general GloBE Rules).
Article 5(b) of the Minimum Tax Act provides that top-up Tax that is subject to the QDMTT is based on the whole amount of the Jurisdictional Top-up Tax calculated, irrespective of the Ownership Interests held in the Constituent Entities located in the QDMTT jurisdiction by any Parent Entity of the MNE Group. This is to apply a provision of the OECD Administrative Guidance which states the QDMTT is not reduced in the case of entities not wholly owned (unlike the general GloBE Rules).
Article 5(c) provides that the accounting standard used to calculate the QDMTT is the UPEs accounting standard. As a QDMTT operates as a credit against the Pillar Two top-up tax liability it should not significantly change the total amount of top-up tax chargeable. The exception to this is where there are differences in GAAP between the UPE and a relevant jurisdiction. By providing that the accounting standard used is the UPE this should standardize the calculation so that there is no excess top-up tax.
In order to avoid circularity, the top-up tax calculation formula for the QDMTT must be amended so that the QDMTT itself is not deducted. Article 5(2)(a) of the Minimum Tax Act provides for this.
Both the GloBE top-up tax and the QDMTT are calculated using a jurisdictional blending approach. Therefore, where there are a number of domestic entities, for QDMTT purposes, one entity can be nominated to bear the QDMTT (with other entities joint and severally liable in the event of non-payment). If no nomination is made, the allocation is based on each entities share of GloBE income based on the entities financial statements.
Article 5(3) of the Minimum Tax Act also provides for a QDMTT exemption for the initial phase of activity (as under the general GloBE rules).
It is expected that an Ordinance will be issued to further detail the QDMTT calculation.
Registration
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 notification to the tax administration within 6 months after the end of the financial year after the group has entered the scope of the GloBE rules in Liechtenstein.
Under Article 14a of the 2025 Amendment Bill, constituent entities located in Liechtenstein that submit a GloBE Information Return (GIR) must register with the tax administration no later than 15 months after the end of the financial year to which the GIR relates.
Filing
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)
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 of 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.
On March 18, 2025, the government approved a draft bill on the amendment of Liechtenstein’s Global Minimum Tax Act (‘the bill’).
The bill is intended to implement domestically the OECD provisions for the exchange of information in the GIR under the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA).
Payment
There are no provisions relating to payment in the current draft law.
Penalties
Detailed penalty rules are provided, however, Article 30 includes transitional penalty relief as provided in the OECD Safe Harbour and Penalty Relief Guidance. As such no penalties will apply for the first 3 years after the law is enacted providing reasonable measures have been taken to comply with the provisions of the Minimum Tax Act.
Failure to submit a GloBE Information Return (intentionally or negligently) can incur a penalty of up to CHF 250,000. Other breaches of procedural rules can incur penalties of of to CHF 10,000.
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 after the group has entered the scope of the GloBE rules in Liechtenstein.
On January 9, 2025, the GloBE Registration form was issued.
| Liechtenstein | |||
|---|---|---|---|
| Effective Date: | Accounting periods beginning on or after January 1, 2024 | ||
| Section/Article | |||
| First Set of OECD Administrative Guidance | |||
| 1.1 | Rebasing monetary thresholds in the GloBE Rules | Transposed Art. 2 of the GloBE Regulation | |
| 1.2 | Deemed consolidation test | Transposed Art. 2 of the GloBE Regulation | |
| 1.3 | Consolidated deferred tax amounts | Transposed Art. 2 of the GloBE Regulation | |
| 1.4 | Sovereign wealth funds and the definition of Ultimate Parent Entity | Transposed Art. 2 of the GloBE Regulation | |
| 1.5 | Clarifying the definition of ‘Excluded Entity’ | Transposed Art. 2 of the GloBE Regulation | |
| 1.6 | Meaning of ancillary for Non-Profit Organisations | Transposed Art. 2 of the GloBE Regulation | |
| 2.1 | Intra-group transactions accounted at cost | Transposed Art. 2 of the GloBE Regulation | |
| 2.2 | Excluded Equity Gains or Loss and hedges of investments in foreign operations | Transposed Art. 2 of the GloBE Regulation | |
| 2.3 | Excluded Dividends- Asymmetric treatment of dividends and distributions | Transposed Art. 2 of the GloBE Regulation | |
| 2.4 | Debt release Election | Transposed Art. 2 of the GloBE Regulation | |
| 2.5 | Accrued Pension Expenses | Transposed Art. 2 of the GloBE Regulation | |
| 2.6 | Covered Taxes on deemed distributions | Transposed Art. 2 of the GloBE Regulation | |
| 2.7 | Excess Negative Tax Carry-forward guidance | Transposed Art. 2 of the GloBE Regulation | |
| 2.8 | Substitute Loss carry forwards | Transposed Art. 2 of the GloBE Regulation | |
| 2.9 | Equity Gain or loss inclusion election | Transposed Art. 2 of the GloBE Regulation | |
| 2.9 | Qualified Ownership Interest/Flow through entity | ||
| 2.1 | Allocation of taxes arising under a Blended CFC Tax Regimes | Transposed Art. 2 of the GloBE Regulation | |
| 3.1 | Application of Taxable Distribution Method Election to Insurance Investment Entities | Transposed Art. 2 of the GloBE Regulation | |
| 3.2 | Exclusion of Insurance Investment Entities from the definition of Intermediate Parent Entity and Partially-Owned Parent Entity | Transposed Art. 2 of the GloBE Regulation | |
| 3.3 | Restricted Tier 1 Capital | Transposed Art. 2 of the GloBE Regulation | |
| 3.4 | Liabilities related to Excluded Dividends and Excluded Equity Gain or Loss from securities held on behalf of policyholders | Transposed Art. 2 of the GloBE Regulation | |
| 3.5 | Simplification for Short-term Portfolio Shareholdings | Transposed Art. 2 of the GloBE Regulation | |
| 3.6 | Application of Tax transparency election to Mutual insurance companies | Transposed Art. 2 of the GloBE Regulation | |
| 4.1 | Deferred tax assets with respect to tax credits under Article 9.1.1 | Transposed Art. 2 of the GloBE Regulation | |
| 4.2 | Applicability of Article 9.1.3 to transactions similar to asset transfers | Transposed Art. 2 of the GloBE Regulation | |
| 4.3 | Asset carrying value and deferred taxes under 9.1.3 | Transposed Art. 2 of the GloBE Regulation | |
| Second Set of OECD Administrative Guidance | |||
| 1 | Currency conversion rules | Transposed Art. 2 of the GloBE Regulation | |
| 2 | MTTCs | Transposed Art. 2 of the GloBE Regulation | |
| 3 | SBIE Rules | ||
| – Foreign rules | Transposed Art. 2 of the GloBE Regulation | ||
| Stock-based compensation election | Transposed Art. 2 of the GloBE Regulation | ||
| Leases | Transposed Art. 2 of the GloBE Regulation | ||
| – Impairment losses inc in tangible asset value | Transposed Art. 2 of the GloBE Regulation | ||
| 4.1 | QDMTT Safe Harbour | Transposed Art. 2 of the GloBE Regulation | |
| 4.2 | UTPR Safe Harbour | Transposed Art. 2 of the GloBE Regulation | |
| Third Set of OECD Administrative Guidance | |||
| 1 | Transitional CbCR – Purchase Accounting Adjustments (consistent reporting condition, goodwill impairment adjustment) | Transposed Art. 2 of the GloBE Regulation | |
| 2.2.1 | Transitional CbCR – JVs | Transposed Art. 2 of the GloBE Regulation | |
| 2.3.1 | Transitional CbCR – Same Financial Statements/Local Financial Statements for Statutory Reporting | Transposed Art. 2 of the GloBE Regulation | |
| 2.3.2 | Transitional CbCR – Using different accounting standards | Transposed Art. 2 of the GloBE Regulation | |
| 2.3.3 | Transitional CbCR – Adjustments to Qualified Financial Statements/Dividend Mismatches | Transposed Art. 2 of the GloBE Regulation | |
| 2.3.4 | Transitional CbCR – MNEs not required to file CbC Reports | Transposed Art. 2 of the GloBE Regulation | |
| 2.3.5 | Transitional CbCR – Qualified Financial Statements for PEs | Transposed Art. 2 of the GloBE Regulation | |
| 2.4.2 | Transitional CbCR – Treatment of Taxes on income of PEs, CFCs, and Hybrid Entities | Transposed Art. 2 of the GloBE Regulation | |
| 2.6 | Transitional CbCR – Treatment of hybrid arbitrage arrangements | Transposed Art. 2 of the GloBE Regulation | |
| 3.1 | Identifying Consolidated Revenue | Transposed Art. 2 of the GloBE Regulation | |
| 3.2 | Mismatch between Fiscal Years of the UPE and another Constituent Entity | Transposed Art. 2 of the GloBE Regulation | |
| 3.3 | Mismatch between Fiscal Year and Tax Year of Constituent Entity | Transposed Art. 2 of the GloBE Regulation | |
| 4.2.1 | Blended CFCs -multiple GloBE Jurisdictional ETRs | Transposed Art. 2 of the GloBE Regulation | |
| 4.2.2 | Blended CFCs – not required to calculate an ETR | Transposed Art. 2 of the GloBE Regulation | |
| 4.2.3 | Blended CFCs – income of non-GloBE Entities | Transposed Art. 2 of the GloBE Regulation | |
| 5.3 | 30 June 2026 Filing deadline | Transposed Art. 2 of the GloBE Regulation | |
| 6 | NMCE Simplified Calcs | Transposed Art. 2 of the GloBE Regulation | |
| Fourth Set of OECD Administrative Guidance | |||
| 1.2.1 | Aggregate DTL Category basis | ||
| 1.2.1 | Exclusion of certain types of GL accounts and separate tracking | ||
| 1.2.1 | Exclusion of GL accounts that generate standalone DTAs | ||
| 1.2.1 | Exclusion of swinging accounts and separate tracking | ||
| 1.2.2 | FIFO/LIFO Basis | ||
| 1.2.3 | Aggregation of Short-term DTLs | ||
| 1.2.2 | Reversal of DTLs that accrued before the Transition Year | ||
| 1.2.2 | 5 year unclaimed accrual election | ||
| 2.1.2 | Recalculated deferred tax where GloBE carrying value differs from accounting carrying value | ||
| 2.1.2 | GloBE and accounting carrying values and the Transition Rules | ||
| 2.1.2 | Additional provisions for Intragroup transactions accounted for at cost | ||
| 2.1.2 | Exclusion of GloBE carrying value from SBIE | ||
| 3.1.3 | General rules for allocating cross-border, current taxes under a cross-crediting corporate tax system: 4 Steps | ||
| 3.1.3 | Specific rules for foreign PEs/CFCs, Hybrids/rev hybrids with domestic source income | ||
| 3.1.3 | Cross-crediting between Permanent Establishments and distributions from foreign subsidiaries | ||
| 4.1 | Extension of the Substitute Loss Carry-forward DTA to PEs, hybrids and rev hybrids | ||
| 4.2 | Allocation of deferred tax expenses and benefits from a Parent Entity to a CFC, PE Hybrid or Rev Hybrid: 5 step process | ||
| 4.2.2 | Five-Year Election to exclude the allocation of all deferred tax expenses and benefits to CFCs, PEs, Hybrids and Rev Hybrids | ||
| 4.2.3 | Exclusion of deferred tax assets or liabilities arising under a Blended CFC regime from transition rules | ||
| 5.2.2 | Determining GloBE status when a Flow-through Entity is held directly by another Flow-through Entity | ||
| 5.3.2 | Non-group owners: Partially owned Flow-through Entities | ||
| 5.3.5 | Non-group owners: Indirect minority ownership | ||
| 5.4.2 | Taxes allocated to a flow-through entity | ||
| 5.5.2 | Hybrid entities – Taxes pushed down include indirect owners | ||
| 5.5.4 | Hybrid entities – Entities located in jurisdictions without a Corporate Income Tax system | ||
| 5.6.2 | Extension of taxes pushed down to include Reverse Hybrids | ||
| 6.1.4 | Option to exclude a Securitization Entity from scope of QDMTT | ||
| 6.1.4 | Option to not impose top-up tax liabilities on SPVs used in securitization transactions | ||
| 6.1.4 | Amendments to the Switch-Off rule | ||
| 6.1.4 | New definition: Securitization Entity | ||
| 6.1.4 | New definition: Securitization Arrangement | ||
| January 2025 OECD Administrtive Guidance | |||
| 1 | Articles 8.1.4 and 8.1.5 | ||
| 1 | Amendments to CbCR Safe Harbour for 9.1 | ||
| 1 | Amendments to QDMTT Safe Harbour for 9.1 | ||
| 1 | Article 9.1 of the GloBE Rules | ||
| 1 | Central Record of Legislation with Transitional Qualified Status |
| Note | Liechtenstein | |
|---|---|---|
| QDMTT?(Enacted/Draft) | Is there a QDMTT in the Legislation? | Yes – Enacted |
| Effective Date: | Accounting Periods beginning on or after January 1, 2024 | |
| Administrative Guidance/Safe Harbour Guidance? | Are the provisions of the OECD Administrative Guidance and Safe Harbour Guidance reflected in the current legislation? | Note yet (a separate Ordinance is required) |
| Separate/Transposed QDMTT | Is the QDMTT a Separate QDMTT or a Transposition of the GloBE Rules (with Amendments) | Transposed |
| Domestic Groups | A QDMTT can also apply to purely domestic groups. | Yes – Article 4(1) |
| Scope Definitions | The definitions of Ultimate Parent Entity, MNE Group, and Constituent Entity correspond with the definitions in the GloBE Rules. | Yes – Transposed under Article 5 |
| Income and covered taxes of Constituent Entities | The QDMTT must compute the tax liability for the jurisdiction by taking into account the income and covered taxes of Constituent Entities under the GloBE Rules. | Yes – Transposed under Article 5 |
| Separate ETRs | A QDMTT must determine a separate ETR and Top-up Tax amount for MOCEs, Joint Ventures and JV Subsidiaries. | Yes – Transposed under Article 5 |
| Charging | A QDMTT must impose a Top-up Tax on one or more domestic Constituent Entities on the Excess Profits of all domestic Constituent Entities, including the domestic Parent Entity. | Yes – Article 4 |
| Enforceability | The legal liability for the domestic top-up tax needs to be enforceable against at least one Constituent Entity in the jurisdiction. | Yes – Joint & Severable |
| Different Accounting Standard? – Optional | Is the use of a local accounting standard optional? | No. Article 5(c) provides that the accounting standard used to calculate the QDMTT is the UPEs accounting standard. |
| Different Accounting Standard? – Mandatory | Is the AG2 guidance followed? | No. Article 5(c) provides that the accounting standard used to calculate the QDMTT is the UPEs accounting standard. |
| Different Accounting Standard? – Default GloBE rules | Do the general GloBE rules apply for the QDMTT accounting standard? | No. Article 5(c) provides that the accounting standard used to calculate the QDMTT is the UPEs accounting standard. |
| Require 100% ownership? | The QDMTT )can require 100% ownership | No |
| Differences to GloBE Rules: tighter restriction is consistent with local tax rules | The QDMTT can be more restrictive than the GloBE Rules where the tighter restriction is consistent with local tax rules. | None |
| Differences to GloBE Rules: Not relevant to in the context of its domestic tax system | The QDMTT can exclude adjustments that are not relevant to in the context of its domestic tax system. | None |
| Income/Loss of a PE | The QDMTT must exclude the income or loss of a foreign Permanent Establishment from the income or loss of the Main Entity. | Yes – Transposed under Article 5 |
| Tax Transparency | A QDMTT must include certain tax transparent provisions. | Yes – Transposed under Article 5 |
| Adjusted Covered Taxes Consistency | The range of taxes included in Covered Taxes needs to be the same or narrower, as under the GloBE rules. | Yes – Transposed under Article 5 |
| GloBE Loss Election? | Not Required in QDMTT | Yes – Transposed under Article 5 |
| No Pushdown to CFC or PE | A QDMTT must exclude: (1) tax paid or incurred by a Constituent Entity-owner under a CFC Tax Regime that is pushed down to a domestic Constituent Entity in the GloBE Rules and (2) tax paid or incurred by a Main Entity that is allocated to a PE in the jurisdiction. | Not Provided |
| Exclude tax allocated to Hybrids | Second AG Guidance | No |
| Exclude allocated net basis tax on dividends (except WHT) | Second AG Guidance | No |
| UPE that is a Flow-Through Entity | Second AG Guidance | Yes – Transposed under Article 5 |
| UPE subject to Deductible Dividend Regime | Second AG Guidance | Yes – Transposed under Article 5 |
| Eligible Distribution Tax Systems | Second AG Guidance | Yes – Transposed under Article 5 |
| ETR Computation for Investment Entities | Second AG Guidance | Yes – Transposed under Article 5 |
| Investment Entity Tax Transparency Election | Second AG Guidance | Yes – Transposed under Article 5 |
| Taxable Distribution Method Election | Second AG Guidance | Yes – Transposed under Article 5 |
| Multi-Parented MNE Groups | Second AG Guidance | Yes – Transposed under Article 5 |
| Additional Top-Up Tax/Excess Negative Tax Expense | A QDMTT needs to have provisions for additional top-up tax where there is no Net GloBE Income and the Adjusted Covered are less than zero and less than the Expected Adjusted Covered Taxes. Amount. Excess Negative Tax Carry-forward rules also need to be in place. | Yes – Transposed under Article 5 |
| Modified Top-Up Tax Formula | The QDMTT top-up tax formula needs to be modified as the GloBE Rules subtract tax paid under a QDMTT from the current GloBE Top-up Tax. | Yes – Article 5 |
| Same Approach As GloBE Rules | A QDMTT must require that top-up tax is taken into account by the relevant Constituent Entity at the same time and in the same manner as under the GloBE Rules (eg it can’t be carried forward). | Yes – Transposed under Article 5 |
| SBIE Included? | Not Required in QDMTT | Yes – Transposed under Article 5 |
| SBIE Rates same as GloBE? | Not Required in QDMTT | Yes – Transposed under Article 5 |
| De Minimis Rule Included? | Not Required in QDMTT | Yes – Transposed under Article 5 |
| Restructuring Rules? | A QDMTT needs to include restructuring rules as provided in the GloBE rules to the extent necessary to conform to the tax reorganization rules in the jurisdiction. | Yes – Transposed under Article 5 |
| Safe Harbours? | A QDMTT needs to contain GloBE safe harbours. | Yes – CbC Safe Harbour Transposed under Article 5 |
| Deferred Tax Transition Rule? | A QDMTT must include the deferred tax starting point under Article 9.1.1 of the Model Rules. | Yes – Transposed under Article 5 |
| SBIE Transitional Rates? | Not Required in QDMTT | Yes – Transposed under Article 5 |
| Initial Phase of International Activity Exemption | Not Required in QDMTT | Yes – Article 5(3) |
| Elections? | Where the GloBE Rules permit an election, a QDMTT must generally also provide for the election and require the MNE Group to make the same election under the QDMTT as is made under the GloBE Rules. | Yes – Transposed under Article 5 |
| Deferred Tax transition: First time or refreshing rule? | Second AG | None |
| New transition year – amend tax attributes? | Second AG | None |
| Currency provisions? | Second AG | Second AG Guidance not followed |
| DTL Recapture rules – Aggregate DTL Categories | Fourth AG, 1.2.8 | |
| DTL Recapture rules Unclaimed Accrual Five-Year Election | Fourth AG, 1.2.8 | |
| Reverse Hybrid Pushdown | Fourth AG, 5.6.2 | |
| Securitization Entities – A QDMTT may also exclude a Securitisation Entity from its scope | Fourth AG, 6.1.4 | |
| Securitization Entities – A jurisdiction may allocate the QDMTT liability for any QDMTT top-up tax to another Constituent Entity (if any) that is located in the jurisdiction | Fourth AG, 6.1.4 | |
| Note |
| Liechtenstein | ||
|---|---|---|
| Effective Date: | Accounting periods beginning on or after January 1, 2024 | |
| Section/Article | ||
| Safe Harbour & Penalty Relief Guidance | De Minimis Test | Transposed – Art. 3 of the GloBE Regulation |
| Safe Harbour & Penalty Relief Guidance | Simplified ETR Test | Transposed – Art. 3 of the GloBE Regulation |
| Safe Harbour & Penalty Relief Guidance | Routine Profits Test | Transposed – Art. 3 of the GloBE Regulation |
| Safe Harbour & Penalty Relief Guidance | Simplified Covered Tax defn (inc exclusion of uncertain tax positions) | Transposed – Art. 3 of the GloBE Regulation |
| Safe Harbour & Penalty Relief Guidance | Simplified ETR defn | Transposed – Art. 3 of the GloBE Regulation |
| Safe Harbour & Penalty Relief Guidance | Transition Period | Transposed – Art. 3 of the GloBE Regulation |
| Safe Harbour & Penalty Relief Guidance | Transition Rate | Transposed – Art. 3 of the GloBE Regulation |
| Safe Harbour & Penalty Relief Guidance | Defn of Qualified Financial Statements | Transposed – Art. 3 of the GloBE Regulation |
| Safe Harbour & Penalty Relief Guidance | Special Rule for Joint Ventures | Transposed – Art. 3 of the GloBE Regulation |
| Safe Harbour & Penalty Relief Guidance | Special Rule for Tax Neutral UPEs | Transposed – Art. 3 of the GloBE Regulation |
| Safe Harbour & Penalty Relief Guidance | Special Rules for Investment Entities and their Constituent Entity-owners | Transposed – Art. 3 of the GloBE Regulation |
| Safe Harbour & Penalty Relief Guidance | Special Rule for Net Unrealised Fair Value Loss | Transposed – Art. 3 of the GloBE Regulation |
| Safe Harbour & Penalty Relief Guidance | Exclusions | Transposed – Art. 3 of the GloBE Regulation |
| December 2023 OECD Administrative Guidance | ||
| 1 | Transitional CbCR – Purchase Accounting Adjustments(consistent reporting condition, goodwill impairment adjustment) | Transposed – Art. 2 of the GloBE Regulation |
| 2.2.1 | Transitional CbCR – JVs | Transposed – Art. 2 of the GloBE Regulation |
| 2.3.1 | Transitional CbCR – Same Financial Statements/Local Financial Statements for Statutory Reporting | Transposed – Art. 2 of the GloBE Regulation |
| 2.3.2 | Transitional CbCR – Using different accounting standards | Transposed – Art. 2 of the GloBE Regulation |
| 2.3.3 | Transitional CbCR – Adjustments to Qualified Financial Statements/Dividend Mismatches | Transposed – Art. 2 of the GloBE Regulation |
| 2.3.4 | Transitional CbCR – MNEs not required to file CbC Reports | Transposed – Art. 2 of the GloBE Regulation |
| 2.3.5 | Transitional CbCR – Qualified Financial Statements for PEs | Transposed – Art. 2 of the GloBE Regulation |
| 2.4.2 | Transitional CbCR – Treatment of Taxes on income of PEs, CFCs, and Hybrid Entities | Transposed – Art. 2 of the GloBE Regulation |
| 2.6 | Transitional CbCR – Treatment of hybrid arbitrage arrangements | Transposed – Art. 2 of the GloBE Regulation |
| January 2025 OECD Administrtive Guidance | ||
| Amendments to CbCR Safe Harbour for 9.1 |
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