"New tax documentation obligations for companies under BEPS"

Liechtenstein participates in the OECD project against base erosion and profit shifting (BEPS). Companies in Liechtenstein must comply with new tax documentation requirements. In 2015, the OECD completed its 15-point program, the effects of which also affect Liechtenstein. In 2016, Parliament passed amendments to the Tax Act that will apply from 2017. These include the correspondence principle, the abolition of the IP box with transitional periods and the exchange of tax rulings. From 2017, companies must document the arm's length nature of transfer prices. Few companies are affected by country-by-country reporting (CbC reporting), which is regulated by a special law. Multinational companies based in Liechtenstein with a turnover of over CHF 900 million must submit country-by-country reports to the tax administration. The latter forwards the information to authorities in partner countries. BEPS affects tax planning, compliance management and management responsibilities. Boards of directors must also face up to increasing tax transparency and an increase in tax disputes.

Topics in the publication

• OECD BEPS projects
• Changes to the tax law
• Correspondence principle and IP box
• Transfer pricing documentation
• Country-by-country reporting (CbC reporting)
• Transmission of group information
• Effects on companies
• Tax transparency and disputes