In its meeting on 18 March 2025, the Government approved the consultation report on amendment of the Law on the Minimum Taxation of Large Enterprise Groups (GloBE Act). The minimum taxation developed by the OECD/G20 Inclusive Framework on BEPS stipulates that multinational enterprise groups with revenue of more than 750 million euros are subject to an effective tax rate of 15%.

Effective 1 January 2024, Liechtenstein introduced the global minimum taxation of large enterprise groups in accordance with the OECD/G20 standard. The standard also includes the automatic exchange of GloBE information between the countries and jurisdictions in which the group operates. The legal basis for this exchange of information is provided by the Multilateral Convention on Mutual Administrative Assistance (MAC) and the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA).

The GIR MCAA was published by the OECD/G20 on 15 January 2025 and is expected to be signed over the course of 2025 by the countries and jurisdictions that have implemented minimum taxation. The first exchange of GloBE information under the GIR MCAA is expected to take place in 2026. To facilitate the implementation of the GIR MCAA, this bill proposes amendments to the existing GloBE Act.

In particular, the amendments to the GloBE Act set out the obligations of Liechtenstein filing constituent entities, the transmission of information from the GloBE information return by the Fiscal Authority, confidentiality, the use of information, secrecy requirements and inspections, the applicable procedures, and penalties for infringements.

The consultation report can be obtained from the Government Chancellery or at www.rk.llv.li (Consultations).