Liechtenstein Amends GloBE Regulation for Side-by-Side Arrangement

Liechtenstein has published the Regulation of 31 March 2026 on amendments to the GloBE Regulation. Article 3 (Safe Harbour) of the GloBE Regulation is amended to essentially allow for the application of certain aspects of the Side-by-Side arrangement agreed to by the BEPS Inclusive Framework in January 2026. This includes that supplementary taxes (top-up taxes) can be determined using:

• Transitional CbCR Safe Harbour rules;
• QDMTT Safe Harbour rules;
• Side-by-Side Safe Harbor rules;
• UPE Safe H…