Transfer Pricing Documentation – Implementation in Liechtenstein

The OECD has developed a new approach to Transfer Pricing Documentation under the BEPS project. The three-tiered documentation approach consists of Country-by-Country Reporting (CbCR), master documentation (master file) and country-specific documentation (local file). Country-by-Country Reporting as well as the statutory general requirement to document transfer prices were already introduced in Liechtenstein on 1 January 2017. The Tax Ordinance [SteV] now regulates how transfer prices are to be determined and how their documentation must be prepared. The Tax Ordinance entered into force on 1 January 2018 and applies to the tax year 2018 for the first time.