Liechtenstein

Anti-avoidance rules for dividend income and capital gains

The anti-avoidance rules on dividend income and capital gains apply as follows:

• Dividend income and capital gains deriving from investments in foreign legal entities are not tax-exempt for income tax purposes if more than 50% of the total income of the foreign legal entity consists of passive income and its taxable income is subject, directly or indirectly, to low taxation.
• For participations owned before 1 January 2019, the anti-avoidance rules did not apply if a dividend income or capital gain was realised before 31 December 2021. As of 1 January 2022, regular anti-avoidance rules apply to such participations.

Organisation for Economic Co-operation and Development (OECD) Global Minimum Tax

As of 1 January 2024, Liechtenstein groups and companies (incl. trusts, establishments or foundations), with gross revenue of more than 750 million EUR, are subject to the global minimum tax (GloBE) of 15%, more precisely a Qualified Domestic Minimum Top-up Tax (QDMTT) and the Income Inclusion Rule (IIR) (see PwC Pillar Two Country Tracker).

The effective date of the Undertaxed Payments Rule (UTPR) has not been implemented yet. As such, it remains open whether and when UTPR may be introduced.

Liechtenstein entities within the scope of Pillar 2 must register within six months of the first financial year being in scope for GloBE. The FL GloBE Registration Form is available on the tax authority's website.

The first GloBE Information Return (GIR) is due within 18 months (15 months for subsequent years), while the Liechtenstein QDMTT and IIR returns are due within 12 months following the financial year-end. Extensions are available upon written request.