The Liechtenstein tax authorities published a GloBE registration form on 9 January 2025. Multinational enterprise groups (MNE groups) that fall within the scope of the Pillar Two rules must register their constituent entities (CEs) using this form within six months after the end of the fiscal year in which the group became subject to Pillar Two, with penalties applying for noncompliance.
Liechtenstein entities (including foundations and trusts) that are part of an MNE group that have annual revenues of EUR 750 million or more in at least two of the four prior fiscal years are subject to Liechtenstein’s Pillar Two rules, which are comprised of a qualified domestic minimum top-up tax (QDMTT) and an income inclusion rule (IIR), as from 1 January 2024. Liechtenstein has not introduced an undertaxed profits rule.
The first Liechtenstein QDMTT/IIR return is due within 12 months after the financial year end, i.e., by 31 December 2025, with an extension available upon request. The first GloBE information return is due within 18 months after the financial year end, i.e., by 30 June 2026. It should be noted, however, that information related to Pillar Two may need to be taken into account for the financial statements for 2024.
MNE groups falling within the scope of the Pillar Two rules by the end of fiscal year 2024 must register in Liechtenstein by 30 June 2025 using the GloBE registration form. They must identify the CEs in the country and provide their names, addresses and characteristics (i.e., ultimate parent entity, partially owned parent entity, etc.). The group must also specify the CE in Liechtenstein that will submit the QMDTT and IIR tax return and which group entity will submit the GloBE information return.
Patrick Müller
BDO in Switzerland
Liechtenstein entities (including foundations and trusts) that are part of an MNE group that have annual revenues of EUR 750 million or more in at least two of the four prior fiscal years are subject to Liechtenstein’s Pillar Two rules, which are comprised of a qualified domestic minimum top-up tax (QDMTT) and an income inclusion rule (IIR), as from 1 January 2024. Liechtenstein has not introduced an undertaxed profits rule.
The first Liechtenstein QDMTT/IIR return is due within 12 months after the financial year end, i.e., by 31 December 2025, with an extension available upon request. The first GloBE information return is due within 18 months after the financial year end, i.e., by 30 June 2026. It should be noted, however, that information related to Pillar Two may need to be taken into account for the financial statements for 2024.
MNE groups falling within the scope of the Pillar Two rules by the end of fiscal year 2024 must register in Liechtenstein by 30 June 2025 using the GloBE registration form. They must identify the CEs in the country and provide their names, addresses and characteristics (i.e., ultimate parent entity, partially owned parent entity, etc.). The group must also specify the CE in Liechtenstein that will submit the QMDTT and IIR tax return and which group entity will submit the GloBE information return.
Patrick Müller
BDO in Switzerland