Liechtenstein

Transfer Pricing in Liechtenstein

Prepare 2026 Liechtenstein transfer pricing workpapers under SteG article 49, SteV articles 31a-31b and 36d, and the Country-by-Country Reporting Act. Covers the arm's-length rule for related parties and permanent establishments, related persons, the OECD methods, the Master File and Local File for groups over CHF 900 million (goods over CHF 1 million, other items over CHF 250,000), the separate route for entities exceeding all PGR article 1064(2) size criteria (CHF 500,000 / CHF 125,000), the residual evidence duty, the 60-day request deadline, CbC reporting (registration, 12-month filing, XML upload, fines up to CHF 250,000) and corresponding adjustments.