Liechtenstein – Deemed Supplier Rules for Electronic Platforms

Based on the VAT treaty between Switzerland and Liechtenstein, Liechtenstein incorporated the VAT amendments previously adopted by the Swiss Parliament into its national law. A partial revision of the Swiss VAT Act, adopted in June 2023, introduced the VAT liability for electronic platforms that facilitate supplies of goods to customers based in the country. 

To address this important tax provision, Liechtenstein has adopted the amendment of the VAT Act. This amendment introduced new rules for electronic platforms, new place of supply rules for providing services, and other VAT-concerned measures. 

Timeline

The amendment of the VAT Law came into effect on January 1, 2025. 

Electronic Platforms and Tax Collection 

Impact and Changes 

New VAT rules in Liechtenstein introduce tax responsibilities for electronic platforms that facilitate the supply of goods and other non-VAT-exempt deliveries. Domestic electronic platforms become liable for VAT collection if they reach the annual threshold of CHF 100,000 for attributable deliveries of goods and other sales not exempt from VAT.

Foreign electronic platforms (under distance sales rules) become VAT collectors if they generate more than CHF 100,000 from the delivery of low-value goods or if they are considered importers of record based on the declaration of subordination. 

An electronic platform that is VAT registered becomes responsible for VAT collection instead of the third-party providers, who are, from the “civil” law perspective, actual suppliers. This derogatory provision introduces two separate transactions: 

• Sale from supplier (underlying supplier) to electronic platform (this supply is treated as VAT-exempt or supply abroad);
• Sale from VAT registered electronic platform (responsible party for VAT collection) and buyer(this supply is taxable).

Third-party suppliers should know their joint responsibility for VAT collection for supplies made through electronic platforms. The best practice would be to perform due diligence on the terms and conditions of the electronic platform to verify its VAT status before making supplies in the country.

The electronic platform that only facilitates the supplies of low-value goods to customers based in Liechtenstein, after reaching the CHF 100,000 threshold, should be aware that from that moment on, all supplies of goods made through the platform are taxable, not just direct or third-party supplies of LVG.

Starting from January 1, 2025, electronic platforms that facilitate attributable deliveries of goods and/or other supplies to customers based in Liechtenstein should establish a new tax collection and reporting system if they haven’t done so already. 

Besides this, the platforms responsible for VAT collection and reporting should also get familiar with the customs and export technicalities that should be put in place when they are positioned as VAT agents for the underlying supply or if they have made a subordinate declaration.