LIECHTENSTEIN Law and Practice Contributed by: Andreas Schurti and Simon Oberhofer, Schurti Partners Attorneys at Law Ltd
9.11 Country-by-Country Reporting and Transparency Provisions Group parent entities residing in Liechtenstein with a consolidated revenue of more than CHF900 million or surrogate parent entities must comply with country- by-country reporting. The reports must be submitted to the Liechtenstein tax authority. 9.12 Digital Economy Businesses Liechtenstein has not yet taken any action with regards to the taxation of digital economy businesses. 9.13 Approach to Digital Services Taxation Liechtenstein has not yet taken any action with regards to digital services taxation. 9.14 Offshore IP Provisions There is no special taxation of offshore intellectual property deployed to Liechtenstein. However, royal - ties are considered passive income in Liechtenstein, meaning that dividends from foreign companies in low-tax jurisdictions are taxable if the passive income of the foreign company accounts for more than 50% of its total income.
entities are not tax-exempt if the foreign entity is low taxed and sustainably earns more than 50% passive
income (see 2.7 Capital Gains ). 9.9 Anti-Avoidance Rules Double Taxation Agreements
Private Asset Structures (see 2.3 Special Incentives ), which are subject only to the minimum corporate income tax of CHF1,800, cannot benefit from the dou - ble tax treaties – eg, with Switzerland, Austria, the Czech Republic, Germany and the United Kingdom. MLI Furthermore, the MLI (to which Liechtenstein is a par - ty) includes the principal purpose test, which hinders the use of layered structures based on the provisions of multiple tax treaties. 9.10 Transfer Pricing and IP Taxation Liechtenstein abolished the IP Box regulation with effect from 1 January 2017, as it did not comply with the OECD standard (BEPS Action 5) (see 2.2 Technol- ogy Investments ).
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