Liechtenstein
Veranlagung nach pflichtgemässem Ermessen — assessment at the authority’s dutiful discretion
Findings at a glance
- Traceability of the calculation
- Business-specific benchmark
- Requirements for counter-evidence
- Burden of proof and its reversal
- Intensity of judicial review
3× exceeded · 2× met
Traceability of the calculationexceeded
Where the taxpayer has filed no return, or where the tax base cannot be determined without objection for want of reliable and complete records, the tax administration assesses at its dutiful discretion.
CitationSteuergesetz (SteG) Art. 102 Abs. 2
What we provideEvery figure is traceable down to the individual document. The chain of calculation can be walked in both directions — from the result to the document and back.
Requirements for counter-evidenceexceeded
A discretionary assessment may be challenged ONLY on the ground of manifest incorrectness. The objection must contain the requests and their reasons, stating the evidence; the evidence must be named and enclosed.
CitationSteuergesetz (SteG) Art. 116 Abs. 2 und Abs. 3
What we provideA closed system: purchasing, production, masses, unit counts, sales channel and revenue support one another. A single incorrect figure shows up against the others.
Further information — 3 axes
Business-specific benchmarkexceeded
In doing so the administration may take into account experience figures, changes in assets and the taxpayer’s cost of living.
CitationSteuergesetz (SteG) Art. 102 Abs. 2
What we provideThe calculation rests on the recipes and quantities of the audited business, not on an industry average.
Burden of proof and its reversalmet
Where the assessment is discretionary, challenge is limited to manifest incorrectness; otherwise all defects may be raised.
CitationSteuergesetz (SteG) Art. 116 Abs. 3
What we provideThe evidence is prepared so that the reversal of the burden remains traceable and the counter-evidence engages with the calculation, not with the objection.
Intensity of judicial reviewmet
Where the objection is directed against a fully reasoned decision, it is to be forwarded as an appeal to the national tax commission on request or with the objector’s consent.
CitationSteuergesetz (SteG) Art. 116 Abs. 4
What we provideThe dossier is built so that a court can follow it without having to calculate anything itself.