Amendment of the GloBE Act to incorporate new safe harbour provisions
Vaduz (ots)
On 7 July 2026, the Government approved the report and motion on the amendment of the Law on the Minimum Taxation of Large Enterprise Groups (GloBE Act) and of the Law on International Automatic Exchange of Information in Tax Matters (AEOI Act).
The proposal primarily aims to enhance legal certainty, efficiency, and planning reliability in the field of global minimum taxation.
Since 1 January 2024, Liechtenstein has implemented the global minimum taxation for large enterprise groups in accordance with the GloBE Model Rules by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (IF on BEPS). These rules include provisions that, under certain conditions, allow for a simplified calculation of top-up taxes-referred to as "safe harbour" rules-thereby providing administrative relief for the affected enterprise groups. In early 2026, the Inclusive Framework on BEPS introduced comprehensive updates to these provisions. As a result, corresponding amendments to national legislation are required.
New safe harbour rules
The newly introduced measures include, in particular, the Side-by-Side Safe Harbour, which provides a broad exemption for enterprise groups with a US ultimate parent entity in order to compensate for the effects of US controlled foreign company rules. In addition, a Simplified Effective Tax Rate (ETR) Safe Harbour will allow for a streamlined calculation of the effective tax rate in high-tax jurisdictions where a full calculation under the GloBE Model Rules is expected to result in an effective tax rate of at least 15%. Furthermore, the existing Transitional Country-by-Country Reporting (CbCR) Safe Harbour will be extended by an additional year. The Substance-Based Tax Incentives Safe Harbour will also offer relief for tax incentives that are linked to genuine economic substance.
Liechtenstein's introduction of the safe harbour rules represents a key prerequisite for maintaining the qualified status granted by the Organisation for Economic Co-operation and Development (OECD) in relation to the implementation of global minimum taxation. It also ensures that administrative simplifications can be effectively applied to the enterprise groups concerned.
In addition, an incorrect reference in the Automatic Exchange of Information (AEOI) Act is to be corrected.
Contact:
Ministry of General Government Affairs and Finance
Eve Beck, Secretary General
T +423 236 74 37
eve.beck@regierung.li