Liechtenstein Transfer Pricing Documentation Requirements
Liechtenstein requires a Master File and Local File from entities above the turnover threshold tied to its Country-by-Country reporting regime, and requires transfer pricing documentation more broadly from large companies that meet a size test even where they fall below the group threshold.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Turnover > EUR 900m, or large companies exceeding two of: balance sheet CHF 30m, net sales CHF 60m, or 250 employees | By the return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. | DE / EN | Not captured |
Local File Required | Same thresholds as the Master File | By the return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. | DE / EN | Not captured |
CbC report Required | Group revenue ≥ CHF 900m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Liechtenstein deadline
Enter your entity’s fiscal year-end to return your exact Liechtenstein preparation or filing date. Available without registration.
Scope of the documentation obligation
A Liechtenstein entity falls within the Master File and Local File requirement where its turnover exceeds the threshold tied to the group reporting regime. The obligation extends further than the group threshold alone: a taxpayer that is not a member of a group meeting that threshold must still maintain transfer pricing documentation where it qualifies as a large company, defined by exceeding two of three criteria, a balance sheet of CHF 30 million, net sales of CHF 60 million in the previous year, or 250 average employees. The documentation is held available by the return filing date.
Distinctive features of the Liechtenstein regime
The defining feature of the Liechtenstein regime is the dual basis on which documentation is required. The formal Master File and Local File attach at the high turnover threshold associated with the group reporting regime, but the size-based test brings large standalone companies into a documentation obligation independently, so an entity can be required to document either because of its group’s scale or because of its own. This widens the population beyond the largest groups to include substantial domestic companies that meet the size criteria.
Benchmarking and comparables
Liechtenstein follows the OECD approach to documentation and comparability. Detailed local practice on the choice between local and foreign comparables, on single-year versus multi-year testing, and on the frequency of fresh searches is applied consistently with the OECD framework, and an in-scope entity is expected to support its pricing with a comparability analysis on that basis.
Frequently asked questions
Can a standalone Liechtenstein company be required to document even below the group threshold?
Yes. A large company that exceeds two of three size criteria, a balance sheet of CHF 30 million, net sales of CHF 60 million, or 250 employees, must maintain transfer pricing documentation even if it is not part of a group meeting the higher turnover threshold.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.