News Overview

By amending the Act on International Administrative Assistance in Tax Matters (Tax Administrative Assistance Act; SteAHG) a legal basis for executing the spontaneous information exchange will be created in Liechtenstein. This newsletter is intended to provide a first overview of the planned amendments to the law. The details of the bill are set out in the Report and Motion (BuA) no. 51/2017.

Country-by-Country (CbC) Reporting is part of Action 13 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Action Plan. CbC Reporting requirements apply to MNE groups with annual consolidated group revenue of CHF 900 million or more in the preceding fiscal year. For the implementation of CbC Reporting in Liechtenstein please see the following Newsletter.

In case VGH 2017/011 the Administrative Court of the Principality of Liechtenstein ruled whether a Liechtenstein foundation fulfills the requirements for taxation as a Private Asset Structure (PAS) under article 64 Tax Act. In particular, the question was whether a foundation with PAS status may participate in a German GmbH & Co. KG (limited partnership with a limited liability company as general partner).