Pillar Two GloBE registration was launched in Liechtenstein

What should I already know?

 

• Liechtenstein entities (including foundations and trusts) that are part of a multinational enterprise ("MNE Group") that have annual revenue of EUR 750m or more in at least two of the four prior fiscal years are subject to a Qualified Domestic Minimum Top-up Tax (QDMTT) as well as the Income Inclusion Rule (IIR) from January 1, 2024. Liechtenstein has not introduced a UTPR for the time being. More information can be found on the official government website on this topic . 
• The first Liechtenstein QDMTT or IRR return is due within 12 months after the financial year end, i.e. December 31, 2025. An extension is available upon request. The first GloBE Information Return (GIR) on the other hand is due within 18 months after the financial year end, i.e. June 30, 2026. However, information related to Pillar 2 may already need to be considered for the financial statements for 2024. 

What ist this year`s new so far?

 

• On January 15, 2025, the OECD has released 6 additional publications with more than 300 pages of guidance related to the GIR and three Administrative Guidance documents that were addressed separately in an update.
• The Liechtenstein tax authorities have published a "GloBE Registration Form"on January 9, 2025. Prior to filing the QDMTT or IIR declarations, Groups subject to Pillar 2 are required to register their so-called constituent entities through this form within 6 months after the end in which the MNE Group has become subject to Pillar 2.
• Entities that do not comply with these registration requirements can get a penalty up to CHF 10k. There can also be a penalty up to CHF 250k if GloBE returns are not submitted.

What do I need to do?

 

• MNE Groups falling under the Pillar 2 requirements by financial year end 2024 must register in Liechtenstein until June 30, 2025, using the GloBE Registration Form.
• For the registration, the MNE Group needs to determine the constituent entities in Liechtenstein, give its names, addresses as well as characteristics (UPE, POPE, etc.) Also, the ultimate parent entity (UPE) of the MNE Group needs to be provided.
• Further, the Group needs to clarify which constituent entity in Liechtenstein will submit the QDMTT and IRR tax return and which Group entity will submit a GIR.

BDO can support.

 

• We recommend reviewing and start the registration process now. This process is also mandatory for entities of a MNE Group that will apply the Transitional CbCR Safe Harbours or are exempt for Pillar 2 purposes.
• BDO can support you during the registration process and can also handle this process for you as your tax representative.
• Please reach out to us for any questions on this matter or if you want us to provide further clarification on how your company is impacted by Pillar 2.