🇱🇮 LI – Liechtenstein Finalizes PCbCR Legislation, Expanding Transparency for MNEs

VADUZ – Liechtenstein Enacts EU Public Country-by-Country Reporting Law, Tightening Tax Transparency for MNEs

Liechtenstein has officially incorporated the EU Public Country-by-Country Reporting (PCbCR) Directive into national law, marking a major step toward increased tax transparency. Effective 1 July 2024, the new legislation mandates that certain multinational enterprises (MNEs) publicly disclose detailed income tax data, provided their global consolidated revenues exceed EUR 750 million. However, the law’s full implementation still awaits formal approval by the EEA Council.

The amendment to Liechtenstein’s Law on Persons and Companies (PGR) aligns the country with EU-wide tax transparency efforts and will impact MNEs operating within or through the principality.

What Is the EU PCbCR Directive?

The EU PCbCR Directive, in force since December 2021, requires large MNEs to publish an annual report detailing income tax data, including:

• Revenues (including intra-group)
• Pre-tax profits
• Income tax paid and accrued
• Number of employees
• Business activities and accumulated earnings

These disclosures must be provided per EU/EEA country and jurisdictions listed as non-cooperative for tax purposes. Reports covering other jurisdictions may be aggregated.

MNEs must publish these reports within 12 months of the financial year-end, though individual EU/EEA states may enforce earlier deadlines. The rules apply to fiscal years starting on or after 22 June 2024.

Liechtenstein’s Implementation Timeline

Who Must Report in Liechtenstein?

Liechtenstein’s PCbCR legislation targets:

• MNE Groups with a UPE in Liechtenstein and consolidated revenue > EUR 750M in each of the last 2 fiscal years
• Medium or large subsidiaries or qualifying branches of non-EU/EEA MNEs located in Liechtenstein

Notably, the EUR 750M threshold is lower than Liechtenstein’s existing CHF 900M CbCR threshold, broadening the pool of impacted entities.

Covered Legal Forms

Only EU-harmonized legal forms are subject to PCbCR in Liechtenstein:

• AG (Aktiengesellschaft / Public Limited Company)
• GmbH (Private Limited Company)
• KAG (Kommanditaktiengesellschaft / Association by Shares)

Other typical Liechtenstein structures—Anstalt, Stiftung, and Trusts—are not subject to PCbCR, unless indirectly through group structure rules.

Key Considerations for MNEs in Liechtenstein

1️⃣ UPE as “Non-Qualified” Entity (e.g., Anstalt, Stiftung, Trust)

If the UPE is not a qualified legal form, reporting may shift to the next qualifying entity in the group hierarchy that is based in the EU/EEA. The law ensures that reporting obligations cannot be avoided merely due to the UPE’s legal form.

2️⃣ Multiple Qualified Subsidiaries

If a Liechtenstein-based UPE owns multiple qualified subsidiaries (e.g., EU-based GmbHs), combined turnover may trigger reporting, even if individual entities fall below the threshold.

3️⃣ Dual Framework Reporting

Liechtenstein UPEs may either:

• Report under standard CbCR rules (which may apply to more entity types under a “deemed listing provision”); or
• Report under Liechtenstein-specific PCbCR law, applicable only to EU-harmonized legal forms.

Expert Insight

“With Liechtenstein aligning itself with the EU’s public disclosure rules, companies using traditional Liechtenstein structures need to revisit their group reporting obligations,” said Hubert Stadler, Partner, Tax at EY Switzerland.

Markus Koch, Partner, Private Tax Services at EY, added, “This marks a shift where privacy-focused entities such as trusts or stiftungen may no longer offer reporting relief if tied to qualifying subsidiaries elsewhere.”

Impact on Businesses

• Increased compliance burden for MNEs with EU operations and Liechtenstein nexus
• Entities formerly exempt from BEPS-style CbCR may now fall within public disclosure scope
• Risk of reputational exposure from public tax data publication
• Heightened scrutiny from tax authorities, NGOs, and media

What’s Next?

While Liechtenstein’s legislation is in force, the EEA Council’s formal ratification remains the final procedural step. Until then, companies should:

• Conduct group structure reviews to identify reporting responsibilities
• Assess entity forms and revenue thresholds
• Prepare internal reporting systems for the first reporting cycle (likely due end of 2026 for calendar year entities)

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