Updated safe harbour rules require targeted legislative amendments
Vaduz (ots)
As of 1 January 2024, global minimum taxation for large enterprise groups was introduced in accordance with the GloBE Model Rules of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (IF on BEPS). The IF on BEPS is an association of countries and jurisdictions within the framework of the BEPS project. The current rules contain various safe harbour mechanisms, that offer the enterprise groups concerned administrative simplifications. In early 2026, these provisions were comprehensively updated by the IF on BEPS, necessitating a corresponding amendment of the national legal framework.
The revision comprises in particular the new Side-by-Side Safe Harbour, which provides a broad exemption for enterprise groups with a US parent entity on the basis of US controlled foreign company rules. In addition, high-tax countries are afforded a simplified means of demonstrating compliance with the effective minimum tax rate (Simplified ETR Safe Harbour). The existing Transitional CbCR Safe Harbour is extended by a further year. For countries that already apply a qualified domestic minimum top-up tax, the existing safe harbour mechanisms remain unchanged.
The domestic implementation of the international requirements necessitates an amendment of the GloBE Act. The aim is the full transposition of the updated safe harbour rules.
The consultation report can be obtained from the Government Chancellery or via its website at www.rk.llv.li. The consultation period ends on 11 May 2026.
Contact:
Ministry of General Government Affairs and Finance
Eve Beck, Secretary General
T +423 236 74 37
eve.beck@regierung.li