At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-27. Tax authority: Steuerverwaltung des Fürstentums Liechtenstein (Tax Administration). Summaries are simplified; check the linked official source before relying on them.
The law
#Liechtenstein sets the arm's length rule in Art. 49 of the Tax Act (SteG, LR 640.0): income and expenses with related persons and permanent establishments are set as if between independent third parties. The Government must issue the details by ordinance, and it did so in Art. 31a and 31b of the Tax Ordinance (SteV, LR 640.01, in force for tax years from 2018). Taxpayers must apply the current OECD Transfer Pricing Guidelines. Art. 63 SteG gives relief for a foreign price correction where there is no tax treaty, and Art. 93a SteG allows binding rulings on request.
Documentation
#A taxpayer in a group with consolidated revenue of more than CHF 900m must keep a master file and local file in line with the OECD Guidelines (Art. 31b(2) SteV). Only cross-border deals above CHF 1,000,000 a year for goods or CHF 250,000 a year per category for other items, per related person, must be documented (Art. 31b(3)). A taxpayer outside such a group that exceeds all the size criteria of Art. 1064(2) PGR must keep a single documentation with lower limits of CHF 500,000 and CHF 125,000 (Art. 31b(4) and (5)). The documentation must be handed to the Tax Administration within 60 days of a request, in German or English, and the law gives no deadline for preparing it. Smaller deals must still be supported with suitable documents on request (Art. 31b(8)).
Methods
#The taxpayer must choose one of the OECD methods: comparable uncontrolled price, resale price, cost plus, transactional net margin or transactional profit split, or another method if none of these fits (Art. 31b(1) SteV). The choice must reflect the real facts and circumstances of the deal. Related persons include owners, beneficiaries, governing bodies and close personal contacts, and the full documentation duty applies to owners or beneficiaries with at least 25% (Art. 31a and 31b(7) SteV).
Penalties
#There is no special fine for missing transfer pricing documentation. The general rules apply: a fine of up to CHF 1,000, or CHF 10,000 in serious or repeated cases, after a reminder (Art. 135 SteG), an assessment at the authority's discretion where records are missing (Art. 102(2) SteG), and a fine for tax evasion of usually one times the tax avoided, from one third to three times (Art. 137 SteG). A missing CbC report is fined up to CHF 250,000 for intent, CHF 100,000 for negligence and CHF 500,000 for serious or repeated breaches (Art. 20 and 21 CbC-Gesetz). A missing GloBE return is fined up to CHF 250,000 for intent (Art. 15(2) GloBE-Gesetz).
Pillar Two
#The GloBE-Gesetz (LGBl. 2023 Nr. 484, in force 1 January 2024) adds a Liechtenstein top-up tax (QDMTT) and an IIR top-up tax for tax years from 1 January 2024. The UTPR starts only when the Government sets a date by ordinance (no earlier than tax years from 2025). No such ordinance was found, so the tool treats the UTPR as not yet in force. The law covers groups and large domestic groups with revenue of at least EUR 750m in two of the four prior years, and the filings are: a notification within 12 months of the first in-scope year end (Art. 5(3) GloBE-Verordnung), the top-up tax return and the GloBE return, each within 15 months of year end or 18 months for the first return (Art. 5(2) and 6(2)), and a registration of the reporting entity within the same periods (Art. 14a GloBE-Gesetz), with payment following the assessment. Fines for breaches in the first three years are waived if reasonable steps were taken (Art. 29 GloBE-Gesetz). Safe harbours include the transitional CbCR safe harbour for years that begin by 31 December 2027 and end by 30 June 2029 (Art. 3 GloBE-Verordnung).
Other rules
#Liechtenstein corporate income tax is 12.5% of taxable net income (Art. 61 SteG). Groups with consolidated revenue above CHF 900m file a CbC report within 12 months of year end, and the reporting entity registers by the last day of the reporting period (Art. 6 and 7 CbC-Gesetz). The Liechtenstein CbC threshold is in Swiss francs, as Liechtenstein uses the Swiss franc. The Tax Administration sets the return deadline each year (Art. 95 SteG). The tool shows each date as set by law and does not move dates that fall on a weekend or holiday, because it is not confirmed that the court holiday rule (Art. 46 LVG, § 126(2) ZPO and Art. 1 FAHG) covers these filing deadlines.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | CbC registration of the reporting entity (Registrierung) A reporting entity must register with the Tax Administration, without being asked, by the last day of the reporting tax period (Art. 7(2) CbC-Gesetz). The law has no notification duty for other Liechtenstein group members. A fine of up to CHF 20,000 applies for intentional failure (Art. 20(2)(a)). The date is the last day of the period itself and is not moved, because the duty must be met within that period. | Last day of the fiscal year (e.g. Dec 31, 2025) | Reporting entities resident in Liechtenstein (the ultimate parent, or a surrogate parent) of groups with consolidated revenue above CHF 900m in the previous reporting year. | Art. 7 CbC-Gesetz (gesetze.li) |
| 2 | Corporate income tax return (Steuererklärung der juristischen Personen) The law does not fix a date. The Tax Administration sets the filing deadline each year (Art. 95(1) SteG). Secondary sources give 1 July of the year after the fiscal year end, so that date is used here. For a year end other than 31 December, the return covers the business year that ends in the calendar tax year (Art. 47(6) SteG), so it is due in the following year. On a reasoned written request the deadline can be extended, at most to 31 December of the year after the tax year, and the provisional invoice must be paid first (Art. 42 SteV). Missing filings can be fined up to CHF 1,000, or CHF 10,000 in serious cases, after a reminder (Art. 135 SteG), and the tax can be assessed at the authority's discretion (Art. 102(2) SteG). | Extended: on a reasoned written request filed before the current deadline, and only if the provisional invoice is paid; the Tax Administration grants at most until 31 December of the year after the tax year (Art. 42 SteV and the Tax Administration's online extension service). A further extension is possible only in special cases (e.g. Dec 31, 2026); original due date Jul 1, 2026 | All legal entities subject to Liechtenstein corporate income tax. The return is filed electronically (Art. 42a SteV). | Fristverlängerung Steuererklärung juristische Personen (Liechtenstein National Administration); Art. 95 SteG and Art. 42 SteV |
| 3 | Country-by-country report (länderbezogener Bericht) Filed with the Tax Administration within 12 months after the end of the reporting tax period (Art. 6(4) CbC-Gesetz), in German or English, in the OECD XML format (Art. 3 CbC-Verordnung). Where another Liechtenstein group member must file because of a systemic failure in the parent's state (Art. 5(1)(c)), the Tax Administration sets a reasonable deadline. Intentional breach is fined up to CHF 250,000, negligence up to CHF 100,000, and serious or repeated breaches up to CHF 500,000 (Art. 20 and 21). For a 31 December year end the tool shows 31 December. That day is listed in Art. 1 FAHG, so the deadline may move into January, but this is not confirmed, so plan for 31 December. | 12 months after year end (e.g. Dec 31, 2026) | Ultimate parent resident in Liechtenstein, or a Liechtenstein surrogate parent, of a group with consolidated revenue above CHF 900m in the previous reporting year. Other Liechtenstein members file only if the Tax Administration asks, when the parent state does not require or exchange the report. | Art. 6 CbC-Gesetz (gesetze.li) |
| 4 | Top-up tax return for the Liechtenstein top-up tax and the IIR (Steuererklärung Ergänzungssteuer) Filed with the Tax Administration within 15 months after the fiscal year end, or 18 months for the first return after the group enters the scope of the GloBE Model Rules (Art. 5(2) GloBE-Verordnung). That is 31 March 2027 for a calendar 2025 year, and 30 June 2026 was the date for calendar 2024. The Tax Administration can extend the deadline on a reasoned written request, with no length stated. The UTPR return is not yet needed because the UTPR is not in force. | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years, with a constituent entity in Liechtenstein. | Art. 13 GloBE-Gesetz, Art. 5 GloBE-Verordnung (gesetze.li) |
| 5 | GloBE return (GloBE-Erklärung, GloBE Information Return) Filed in the OECD GIR XML format within 15 months after the fiscal year end, or 18 months for the first GloBE return after the group enters scope (Art. 6(2) GloBE-Verordnung). A fine of up to CHF 250,000 applies for intentional failure to file (Art. 15(2) GloBE-Gesetz), but no fines are set for breaches in the first three years of the law if reasonable steps were taken (Art. 29). | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years, with a constituent entity in Liechtenstein. Not needed in Liechtenstein if the parent or a designated entity files it in a state that exchanges it with Liechtenstein. | Art. 13 GloBE-Gesetz, Art. 6 GloBE-Verordnung (gesetze.li) |
| 6 | Registration of the reporting entity for GloBE information exchange (Registrierung) Reporting entities register with the Tax Administration without being asked, within 15 months after the fiscal year end of the GloBE return, or 18 months for the first year after the group enters scope (Art. 14a(2) GloBE-Gesetz). This is the same deadline as the GloBE return. A fine of up to CHF 20,000 applies for intentional failure (Art. 15(3)). | With GloBE return (GloBE-Erklärung, GloBE Information Return) (e.g. Mar 31, 2027) | Reporting constituent entities located in Liechtenstein of groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | Art. 14a GloBE-Gesetz (gesetze.li) |
| 7 | Master file (Master File, Art. 31b SteV) The master file and local file must be kept in line with the OECD Guidelines (Art. 31b(2) SteV). The law gives no date for preparing them. They must be handed to the Tax Administration within 60 days of a request, in German or English (Art. 31b(6) SteV). | Within 60 days of a tax authority request | Taxpayer that is part of a group with consolidated revenue of more than CHF 900m. Only cross-border transactions with a related person or permanent establishment above CHF 1,000,000 a year for goods, or CHF 250,000 a year per category for other income and expenses, must be documented. Related persons count if the holding or benefit is at least 25%. | Art. 31b SteV (gesetze.li) |
| 8 | Local file (Local File, Art. 31b SteV) Prepare it for each year the thresholds are met, in line with the OECD Guidelines (Art. 31b(2) and (3) SteV). It must be handed over within 60 days of a request (Art. 31b(6) SteV). Other related-party transactions below these limits still need to be supported on request with suitable documents (Art. 31b(8) SteV). | Within 60 days of a tax authority request | Same group as the master file: group consolidated revenue of more than CHF 900m, for cross-border transactions above CHF 1,000,000 a year for goods or CHF 250,000 a year per category for other items, per related person or permanent establishment. | Art. 31b SteV (gesetze.li) |
| 9 | Transfer pricing documentation for large standalone taxpayers (Art. 31b(4) SteV) The documentation covers the business and structure, the list of related-party dealings, functions, risks and assets, the method chosen and the analysis behind the prices (Art. 31b(4) SteV). There is no master file. It must be handed over within 60 days of a request, in German or English (Art. 31b(6) SteV). | Within 60 days of a tax authority request | Taxpayer that is not part of a group above CHF 900m but exceeds all the size criteria of Art. 1064(2) PGR. Documentation covers cross-border transactions above CHF 500,000 a year for goods per related person, or CHF 125,000 a year per category for other items. The tool uses the CHF 125,000 figure as a simple proxy. | Art. 31b SteV (gesetze.li) |
| 10 | GloBE notification to the Tax Administration (Mitteilung) One-time notice after the group first falls in scope of the GloBE Model Rules: within 12 months after the end of that fiscal year, without being asked (Art. 5(3) GloBE-Verordnung). Before the April 2025 amendment the period was six months, and the first date was moved to 31 December 2025. A breach after a reminder can be fined up to CHF 1,000, or CHF 10,000 in serious cases (Art. 15(1) GloBE-Gesetz), but no fines apply in the first three years if reasonable steps were taken (Art. 29). | One-time: due only for the first year in scope | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years, with a constituent entity in Liechtenstein. Applies to domestic constituent entities and excluded domestic entities. | Art. 5(3) GloBE-Verordnung (gesetze.li) |
| 11 | Payment of the top-up tax No fixed payment date was found in the GloBE law or ordinance. Art. 12(1) GloBE-Gesetz applies the general procedure rules of the Tax Act (Art. 113 to 120 SteG) with the necessary changes. Under those rules tax is due when the assessment is delivered (Art. 113(2) SteG) and must be paid within 30 days after the due date (Art. 114(1) SteG), with late interest after that. Check the assessment notice for the exact date. | See note | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years, with a constituent entity in Liechtenstein. | Art. 12 GloBE-Gesetz, Art. 113 and 114 SteG (gesetze.li) |
Official texts
#- Steuergesetz (SteG), Steuerverordnung (SteV), CbC-Gesetz, GloBE-Gesetz, GloBE-Verordnung, LVG, ZPO and FAHG (Lilex, gesetze.li) (Not protected by copyright: laws, ordinances and other official acts, and official or legally required translations of them, are excluded from copyright (Art. 5(1)(a) and (2) Urheberrechtsgesetz, LR 231.1))