Liechtenstein 2026: Practical Globe (pillar Two) and CARF Compliance Guide for Fiduciaries, Foundations and Mnes

Last updated: April 30, 2026

Liechtenstein GloBE compliance 2026 has moved from planning to action. Between January and April 2026, the Principality enacted a series of legislative amendments, most notably the Regulation of 31 March 2026 published as LGBl. 2026 Nr. 114, that reshape how MNE groups calculate and report Pillar Two top-up tax, while simultaneously launching a new Crypto-Asset Reporting Framework (CARF) and updated CRS obligations that directly target trustees and foundation administrators. For licensed fiduciaries, the practical implications are immediate: register for Global Information Return (GIR) filing where required, update data-collection workflows for CARF reporting 2026, and review safe-harbour eligibility before the first automatic exchange of GloBE data takes place later this year.

This guide translates every new obligation into step-by-step trustee actions, worked examples and compliance checklists.

What Changed in Liechtenstein in 2026?

Liechtenstein has moved rapidly to align with the OECD’s global minimum tax framework and next-generation transparency standards. The changes arrived in two waves, a CARF regulation in January followed by comprehensive GloBE amendments in March and April, creating a dense compliance calendar that trustees and in-house tax managers must navigate simultaneously.

Timeline of Key Legislative Changes (January–April 2026)

Sources: LGBl. 2026 Nr. 114 (Regulation of 31 March 2026) as cited by Orbitax; Regierung des Fürstentums Liechtenstein; KPMG Taxnewsflash; Chambers & Partners.

What These Changes Mean for Trustees, Foundations and MNEs

• MNE groups with Liechtenstein constituent entities must now prepare and file GIRs, compute top-up tax (or verify safe-harbour eligibility) and maintain documentation that will be exchanged automatically with foreign tax authorities.
• Licensed trustees and foundation administrators face expanded Liechtenstein fiduciary obligations, including CARF/CRS data capture, classification of foundations as financial institutions (FIs), and potential GIR coordination where the trustee administers an MNE group entity.
• CASPs and fiduciaries holding crypto assets must register with the LLV, implement wallet-level KYC and transaction-metadata collection, and prepare for the first CARF exchange in 2027.

Liechtenstein GloBE Compliance 2026, Who Must Act Now

The Pillar Two global minimum tax applies to MNE groups with consolidated revenue of at least EUR 750 million in at least two of the four preceding fiscal years. If the ultimate parent entity (UPE) is resident in Liechtenstein, or if the group has constituent entities (CEs) located in the Principality, specific filing and top-up tax obligations arise.

Ultimate parent entity (UPE) in Liechtenstein: The UPE must file the GIR with the LLV unless it has designated a surrogate filing entity in another jurisdiction that has a qualifying competent authority agreement in place. Even where a surrogate files, the Liechtenstein UPE retains responsibility for ensuring accurate data submission and for paying any domestic top-up tax, including the Qualified Domestic Minimum Top-up Tax (QDMTT).

Constituent entities only: Where the UPE is outside Liechtenstein but the group has CEs in the jurisdiction, trustees and administrators of those CEs must coordinate with the group’s central tax function to provide jurisdiction-level financial data, substance-based income exclusion (SBIE) details and safe-harbour computations.

Trustee-managed structures: A licensed trustee administering a Liechtenstein entity that forms part of an in-scope MNE group may carry operational responsibility for assembling the local data pack. The trustee must verify whether the entity is a CE, whether the group exceeds the EUR 750 million threshold, and whether a GIR filing obligation rests with the Liechtenstein entity or with the group’s UPE elsewhere.

Trustee and Foundation Classification Under CRS / CARF

Separate from Pillar Two, trustees and foundation administrators must determine whether the entities they manage qualify as reporting financial institutions under the updated CRS and the new CARF. The classification drives the scope of due-diligence and reporting obligations. Use the following checklist:

1. Does the foundation or trust hold, manage or administer financial assets for others? If yes, the entity is likely a custodial institution or investment entity and therefore an FI under CRS.
2. Does the entity’s gross income arise primarily (≥50%) from investing, reinvesting or trading financial assets? If yes, it may be classified as an investment entity.
3. Is the entity professionally managed by a trustee or fiduciary that is itself an FI? If yes, the entity is treated as an investment entity managed by another FI and is reportable.
4. Does the entity, or its trustee, hold, transfer or exchange crypto assets on behalf of clients? If yes, CARF obligations apply in addition to CRS, effective from 1 February 2026.

Private foundations that hold only passive investments and are managed by a licensed trustee will typically be classified as investment entities and are therefore reporting FIs. The common assumption that private foundations fall outside FI classification is incorrect in most cases, a point addressed further in the FAQ below.

GIR Filing, Registration, Process and Deadlines

The Global Information Return is the central data submission mechanism under the GloBE framework. For Liechtenstein, the GIR filing process involves registration with the LLV, data preparation and submission in a standardised XML format aligned with the OECD’s GIR schema.

Step-by-Step Registration Checklist

1. Determine filing entity. Confirm whether the Liechtenstein entity is the UPE, designated filing entity or surrogate. If the UPE is abroad and a GIR MCAA is in force with that jurisdiction, the Liechtenstein CE may not need to file locally, but it must still provide data.
2. Register with the LLV. The filing entity must register through the Fiscal Authority’s electronic portal. Registration requires the entity’s legal name, Liechtenstein tax identification number, MNE group name, UPE jurisdiction and the fiscal year to which the GIR relates.
3. Prepare jurisdiction-level data. For each jurisdiction in which the group has CEs, the GIR requires: revenue, profit/loss before tax, income tax paid and accrued, tangible assets, number of employees, and payroll, enabling the Effective Tax Rate (ETR) and top-up tax calculations.
4. Compile entity-level data. Individual CE data must be broken down to support SBIE exclusions and safe-harbour tests.
5. Submit in GIR XML format. The OECD publishes a standardised GIR XML schema. Liechtenstein follows this schema; the LLV portal accepts uploads in this format.
6. Retain records. All supporting calculations, inter-company data requests and correspondence with the group tax function must be retained for the statutory retention period.

GIR MCAA Exchange Timetable

Liechtenstein signed the GIR Multilateral Competent Authority Agreement, enabling automatic exchange of GloBE information with partner jurisdictions. The first exchange is scheduled to take place in 2026, covering the 2024 reporting year. Industry observers expect that the exchange infrastructure will follow the model already in use for CRS, with the LLV acting as the competent authority transmitting data to treaty partners.

Source: Liechtenstein Business, GIR MCAA announcement.

Practical Trustee Actions, Data Inventory and Beneficiary Mapping

Trustees administering CEs face specific data-gathering challenges. Related-party transactions, management fees, royalty flows and interest payments between group entities must be identified, documented and reconciled against consolidated financial statements. Where the trustee is not the group’s central tax function, a formal data-sharing protocol should be agreed with the UPE’s advisors. Common gaps include incomplete transfer-pricing documentation, missing substance evidence (employee headcount, tangible asset schedules) and unreconciled deferred tax positions. Addressing these gaps proactively reduces the risk of penalties and restatements once GIR data enters the automatic exchange pipeline.

Pillar Two Top-Up Tax: QDMTT, Safe Harbour and Calculation Workflow

The core mechanic of the Pillar Two global minimum tax is straightforward in concept: if the effective tax rate (ETR) in a jurisdiction falls below 15%, a top-up tax is charged to bring the rate up to that minimum. In practice, the calculation requires careful layering of adjustments, exclusions and elections.

Liechtenstein has implemented a Qualified Domestic Minimum Top-up Tax (QDMTT), which allows the jurisdiction to collect the top-up tax domestically rather than ceding it to the UPE’s jurisdiction under the Income Inclusion Rule (IIR) or the Undertaxed Payments Rule (UTPR). This means a Liechtenstein CE in an in-scope group will generally pay any top-up tax to the Liechtenstein tax administration rather than to a foreign authority, an important point for trustees managing local cash flows and tax provisions.

Safe-Harbour Regimes, Eligibility Checklist and Impact on Top-Up Tax

The amendment to Article 3 of the GloBE Regulation (LGBl. 2026 Nr. 114) refined the safe-harbour rules applicable to Liechtenstein entities. Safe harbours allow MNE groups to simplify or eliminate the full top-up tax computation where certain conditions are met. There are three principal tests under the transitional Country-by-Country Reporting (CbCR) safe harbour:

• De minimis test: Total revenue in the jurisdiction is below EUR 10 million and profit before tax is below EUR 1 million.
• Simplified ETR test: The simplified ETR (calculated using CbCR data and a qualifying tax rate) is at or above the safe-harbour rate for the relevant fiscal year (15% for fiscal years beginning in 2026 and onwards).
• Routine profits test: Profit before tax is equal to or less than the SBIE amount for the jurisdiction (i.e., all profits are attributable to substance-based carve-outs for payroll and tangible assets).

If any one of these tests is met, the top-up tax for that jurisdiction is deemed to be zero for the fiscal year and the full GloBE computation can be bypassed. The April 2026 amendment clarifies how Liechtenstein entities apply these tests, particularly around the treatment of deferred tax assets and the interaction between the QDMTT and the transitional safe harbour.

Source: Orbitax, Liechtenstein Amends GloBE Regulation; Bergt & Partner, GloBE amendments insight.

Worked Numeric Example, Three-Step Calculation

The following simplified example illustrates the top-up tax workflow for a Liechtenstein CE of an in-scope MNE group.

Step 1, Calculate the jurisdictional ETR.
GloBE income for Liechtenstein CEs: EUR 20,000,000.
Adjusted covered taxes: EUR 2,400,000.
ETR = EUR 2,400,000 ÷ EUR 20,000,000 = 12%.

Step 2, Determine the top-up tax percentage.
Minimum rate (15%) minus jurisdictional ETR (12%) = 3% top-up tax percentage.

Step 3, Compute the jurisdictional top-up tax.
GloBE income (EUR 20,000,000) minus SBIE (assume EUR 5,000,000 for payroll and tangible assets) = excess profit of EUR 15,000,000.
Top-up tax = 3% × EUR 15,000,000 = EUR 450,000.

Under the QDMTT, this EUR 450,000 is payable to the Liechtenstein tax administration. The trustee administering the CE must ensure sufficient cash reserves or request funding from the group, document the computation and retain all supporting schedules.

Comparison: Full Rules vs Safe Harbour

Documentation and audit trail: Whether the full computation or a safe harbour applies, trustees must maintain a complete audit file including: the GloBE income calculation, adjusted covered taxes schedule, SBIE workpaper, safe-harbour test workpaper (if applicable), board minutes or trustee resolution approving the computation, and any correspondence with the group’s central tax function. This file will be subject to review by the LLV and may be shared with foreign tax authorities under the GIR MCAA.

CARF and CRS 2.0, Trustee and Foundation Reporting Obligations

Alongside Pillar Two, CARF reporting 2026 introduces a fundamentally new information-exchange layer for crypto assets, while the CRS 2 implementation extends and modernises the existing Common Reporting Standard. Liechtenstein’s CARF regulation was enacted in January 2026, with effective obligations beginning 1 February 2026. The first automatic exchange of CARF data with partner jurisdictions is scheduled for 2027, covering the 2026 reporting period.

Sources: LLV, CARF page; Chambers & Partners, CARF MCAA & CRS Addendum; KPMG Taxnewsflash, CARF enactment.

Trustee Data-Collection Checklist for CARF / CRS

Trustees and foundation administrators acting as, or on behalf of, reporting FIs must collect and retain the following data for each reportable account or crypto-asset user:

• KYC / identity data: Full legal name, date of birth, tax identification number(s), jurisdiction(s) of tax residence, current residential address.
• Wallet identifiers (CARF): On-chain wallet addresses, custodial account identifiers, internal reference numbers linking wallets to the account holder.
• Transaction metadata (CARF): Gross proceeds from disposals of crypto assets, fair market value of transfers (including crypto-to-crypto), number and type of units transacted, transaction dates.
• Account balance / value (CRS 2.0): Year-end balance of financial accounts, gross amounts of dividends, interest, other income, and gross proceeds from sales or redemptions of financial assets.
• Entity classification (CRS 2.0): Whether the account holder is a passive non-financial entity (NFE) with controlling persons, and the identity and tax residence of each controlling person.

The LLV requires CARF reports to be submitted by 30 June for reporting periods commencing from 2026. Trustees should map these data fields to their existing AML/KYC databases and identify any gaps that require client outreach or system enhancements.

Classification of Foundations and Trustees as FI, Step Checklist

1. Determine whether the entity holds financial assets on behalf of others (custodial institution test).
2. Assess whether ≥50% of gross income derives from financial-asset investment or trading (investment entity test).
3. If the entity is managed by a licensed trustee that is itself an FI, the entity is classified as a managed investment entity.
4. Confirm whether any exclusion applies (e.g., governmental entities, international organisations, qualifying pension funds).
5. If classified as an FI, register with the LLV and apply due-diligence procedures to all pre-existing and new accounts.

CARF vs CRS 2.0, What Trustees Must Collect and Report

Reporting Obligations by Entity Type

Practical Compliance Playbook for Trustees and Administrators

The convergence of Pillar Two and CARF/CRS obligations requires a structured response. The following ten-step checklist provides a practical framework for licensed trustees and foundation administrators to achieve Liechtenstein GloBE compliance 2026 alongside their new reporting duties.

1. Conduct a scope assessment. For every entity under administration, determine whether it falls within the Pillar Two perimeter (MNE group, EUR 750m threshold) and/or CRS/CARF reporting (FI classification).
2. Register with the LLV. Complete GIR registration (if filing entity) and CARF registration (if a reporting crypto-asset service provider or FI holding crypto).
3. Run safe-harbour tests early. Before committing resources to a full GloBE computation, apply the three safe-harbour tests using CbCR data. Document the result even if the test is met.
4. Establish a data-sharing protocol with the group. Where the CE is part of an international MNE group, agree deadlines, data formats and responsibilities with the UPE’s central tax function.
5. Update client onboarding and KYC. Revise onboarding forms to capture CARF data fields (wallet addresses, crypto-asset types, TINs for all jurisdictions of tax residence).
6. Map existing data to GIR and CARF schemas. Identify gaps between current systems and the OECD GIR XML schema and LLV CARF reporting template.
7. Engage tax counsel. Complex issues, particularly QDMTT computation, deferred tax adjustments and safe-harbour interaction, require specialist input.
8. Update trustee agreements and foundation deeds. Ensure governing documents authorise the trustee to collect, process and transmit data required under GloBE and CARF, and to fund top-up tax payments from entity assets.
9. Notify beneficiaries and clients. Where new data collection or tax liabilities arise, communicate promptly (see template below).
10. Build an audit file from day one. Every computation, data request, safe-harbour test and filing should be logged in a central compliance file, timestamped and retained for the statutory retention period.

Template Notice to Clients and Beneficiaries

Suggested wording (adapt to specific circumstances):

“Dear [Client/Beneficiary], as a result of new Liechtenstein legislation implementing the OECD Pillar Two Global Minimum Tax (GloBE) rules and the Crypto-Asset Reporting Framework (CARF), we are required to collect additional information and, where applicable, to file reports with the Liechtenstein Fiscal Authority. We may also need to compute and pay a domestic top-up tax on behalf of the entity. Please provide [specified data/documents] by [date]. If you have any questions, please contact our office.”

Record Retention and Audit Trail Requirements

Liechtenstein fiduciary obligations require trustees to retain all records supporting GIR filings, top-up tax computations and CARF/CRS reports for a minimum period consistent with the general tax statute of limitations. In practice, retaining records for at least ten years is recommended given the potential for cross-border enquiries under the GIR MCAA. Audit files should include source financial statements, tax computation workpapers, safe-harbour test documentation, CbCR data, client correspondence and filed returns with LLV acknowledgement receipts.

Enforcement, Penalties and Risk Mitigation

The LLV has the authority to impose administrative fines for failures to register, file or report under both the GloBE and CARF frameworks. While the specific penalty schedules are set out in the respective regulations, industry observers expect that enforcement will initially focus on registration and filing completeness rather than computational accuracy, reflecting the transitional nature of the regime.

Beyond financial penalties, non-compliance carries significant reputational risk for licensed fiduciaries. The Liechtenstein Financial Market Authority (FMA) may take regulatory action where a licensed trustee fails to meet its legal obligations, potentially affecting the trustee’s licence. Additionally, once GIR data is exchanged automatically, inconsistencies between a Liechtenstein entity’s data and the data filed by other group entities in foreign jurisdictions may trigger cross-border enquiries and transfer-pricing adjustments.

Practical risk mitigation steps:

• Voluntary self-disclosure: Where errors or omissions are identified, proactive disclosure to the LLV before an audit or enquiry can mitigate penalties.
• Technical reconciliation: Reconcile GIR data against CbCR submissions and local tax returns to ensure consistency.
• Engage specialist review: For the first filing cycle, consider engaging an independent review of GIR data, top-up tax calculations and safe-harbour elections before submission.

Next Steps

Liechtenstein GloBE compliance 2026, combined with the simultaneous CARF and CRS 2.0 rollout, represents the most significant expansion of tax reporting obligations in the Principality in over a decade. Trustees, foundation administrators and MNE group tax teams should act now, not at the filing deadline, to avoid compressed timelines and data gaps that lead to penalties and reputational damage.

For a bespoke compliance review tailored to your foundation, trust or MNE structure, consult a qualified Liechtenstein tax and fiduciary specialist. Downloadable GIR data-mapping templates and top-up tax workbook files are available upon request from your local adviser.