Liechtenstein-Anstalt


At one time, the territory of Liechtenstein was part of the ancient Roman province of Raetia. For centuries this territory, geographically removed from European strategic interests, had little impact on European history. Prior to the reign of its current dynasty, the region was enfeoffed to a line of the counts of Hohenems. The Liechtenstein dynasty, from which the principality takes its name, comes from Castle Liechtenstein in Lower Austria, which the family possessed from at least 1140 until the 13th century, and from 1807 onward. Through the centuries, the dynasty acquired vast tracts of land, predominantly in Moravia, Lower Austria, Silesia, and Styria, though these territories were all held in fief under other more senior feudal lords, particularly under various lines of the Habsburg family, whom several Liechtenstein princes served as close advisers. Thus, without any territory held directly under the Imperial throne, the Liechtenstein dynasty was unable to meet a primary requirement to qualify for a seat in the Imperial diet (parliament), the Reichstag. The family yearned for the added power a seat in the Imperial government would bring and therefore sought to acquire lands that would be unmittelbar, or held without any feudal personage other than the Holy Roman Emperor having rights on the land. After some time, the family was able to arrange the purchase of the minuscule Herrschaft ("Lordship") of Schellenberg and county of Vaduz (in 1699 and 1712 respectively) from the Hohenems. Tiny Schellenberg and Vaduz had exactly the political status required: no feudal lord other than their comital sovereign and the suzerain Emperor. On 23 January 1719, after the lands had been purchased, Charles VI, Holy Roman Emperor, decreed that Vaduz and Schellenberg were united and elevated the newly formed territory to the dignity of Fürstentum (principality) with the name "Liechtenstein". It was on this date that Liechtenstein became a sovereign member state of the Holy Roman Empire. Liechtenstein was part of the German Confederation from 1815 to 1866 which was presided over by the Emperor of Austria. In 1860 the Liechtenstein became hereditary members of the upper chamber of the Austrian Parliament. In 1866 the principality became independant. Until the end of World War I, it was closely tied to Austria, but the economic devastation caused by that conflict forced Liechtenstein to enter into a customs and monetary union with Switzerland. During World War II Liechtenstein remained neutral. In 1990 Liechtenstein joined UN, in 1991 – European economic zone, and in 2011 – Shengen zone.

Service packages

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Service item Express Standard Optimum
Company registration
Legal address per year
Secretarial services for the first year
Fees and duties for the first year
Apostilled bound set of incorporation documents
Compliance fee
Nominee service per year
Bank Account Pre-approval
Price

16 880 USD

24 040 USD

24 540 USD

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Contact method: and / or

Core Services

15 290 CHF

— Incorporation

including incorporation tax, state registry fee, including Compliance fee

Included

— Annual government fees

Stamp Duty and Commercial Register incorporation fee

7 700 CHF

— Corporate legal services

including registered address and registered agent, NOT including Compliance fee

110 CHF

—Delivery of documents by courier mail

DHL or TNT, at cost of a Courier Service

550 CHF

— Apostilled set of Statutory documents

Optional services

Nominee Shareholder

Paid-up “nominee shareholder” set includes the following documents

Related services

Tax Certificate

Company’s tax residence certificate for access to double tax treaties network

Certificate of Good Standing

Document issued by a state agency in some countries (Registrar of companies) to confirm a current status of a body corporate. A company with such certificate is proved to be active and operating.

Compliance fee

Compliance fee is payable in the cases of: renewal of a company, liquidation of a company, transfer out of a company, issue of a power of attorney to a new attorney, change of director / shareholder / BO (except the change to a nominee director / shareholder)

250 USD

Basic

simple company structure with only 1 physical person

50 USD

For legal entity in structure under GSL administration

additional compliance fee for legal entity in structure under GSL administration (per 1 entity)

100 USD

For legal entity in structure not under GSL administration

additional compliance fee for legal entity in structure NOT under GSL administration (per 1 entity)

350 USD

For client with high risk Status

Cost of incorporation, including first year servicing 16880
Cost of nominee director services per year, including an apostilled set of documents 7160
Cost of annual service, starting from the second year 8500
Open account in 26772
Incorporation timescale for a turnkey company 10 days
Country 26755

General information shortly

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Total area Population Capital Unemployment Corruption perceptions index rank
160.475 sq. km 37.009 (2013) Vaduz 2.3% (2012) 11 (2013)
Location Central Europe
National currency Swiss franc
Conditional reduction of currency CHF
Against USD 0.88
Climate, average max and min t° Continental; cold, cloudy winters with frequent snow or rain; cool to moderately warm, cloudy, humid summers; avg. maximum temperature (July) +27°; avg. minimum temperature (January) +13°
Time difference from Moscow - 2 hours
Dialing code +423
State language German
Ethnic groups Liechtensteiner 65.6%, other 34.4% (Italian, Swiss, Austrian)
Literacy rate 100%
Credit rating AAA
Government type Constitutional monarchy
Executive branch Government: Prime Minister and 4 government councilors (ministers)
Legislative branch unicameral Landtag (25 members)
Judicial branch the Regional Court at Vaduz, the Princely High Court of Appeal at Vaduz, the Princely Supreme Court, the Administrative Court, and the State Court
GDP per capita rank 1 (2013)

Corporate info

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Shelf companies permitted Legal system Incorporation timescale for a turnkey company Cyrillic alphabet permitted in company name Local registered office
Yes civil law 10 days No Yes
Types of entity Sole Proprietorship, General Partnership (Kollektivgesellschaft), Limited Partnership (Kommanditgesellschaft), Cooperative Society (Genossenschaft), Private limited company (Gesellschaft mit beschränkter Haftung, GmbH), Company limited by shares (Aktiengesellschaft, AG), Establishment (Anstalt), Joint Venture (Einfache Gesellschaft), Branch Office, Trust Company (registriertes Treuunternehmen/Trust reg.), Trust (Treuhänderschaft), Foundation (Stiftung)
Incorporation timescale for a new company 3-5 days
Company suffix ‘Anstalt’ or its foreign language equivalent (English: ‘Establishment’, French: ‘Etablissement’, Italian: ‘Stabilimento’)
Sensitive words national or international state or place names; Liechtenstein, State, Country, Municipality, Principality; Bank, Building Society, Savings, Insurance, Assurance, Reinsurance, Fund Management, Investment Fund, Red Cross
Local registered agent Yes
Information to be kept at the registered office details of the directors, officers and shareholders
Seal required, type of seal not required
Redomiciliation (to, from) permitted permitted

Director and secretary

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Minimum number of directors Residency requirements for directors Corporate directors permitted Disclosure to local agent Disclosure to public
1 Yes Yes No Yes
Directors’ meetings/frequency/location No requirements
Company secretary required No
Residency requirements for a secretary No
Qualified secretary required No
Corporate secretary permitted No

Shareholder and beneficiary

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Minimum number of shareholders Residency requirements for shareholders Corporate shareholder permitted Disclosure to local agent Disclosure to public
1 No Yes Yes No
Meetings/frequency/location No requirements
Beneficiary info disclosure to No

Shares and share capital

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Minimum authorized share capital Minimum issued share capital Minimum paid share capital Authorized capital payment deadlines Bearer shares permitted
30000 30000 30000 Upon registration Yes
Issued capital payment deadlines Upon registration
Standard currency Swiss franc
Standard authorized share capital 30000
Standard par value of shares 100
Shares with no par value permitted Yes

Taxes

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Min. rate for corporate tax Capital gains tax VAT Withholding tax Exchange control
12,5% Regular rate 7,7% No No
Personal tax 2,5-22,4%
Corporate tax (in detail) Companies pay income tax at a rate of 12.5%. There is a minimum tax of CHF 1,800, which can be read out against income tax.
Capital gains tax. Details Capital gains are included in chargeable income, except for those arising from the sale of real estate and to which Liechtenstein real estate property tax is applied.
VAT. Details The standard VAT rate is 7.7%. For some goods and services - 2.5% and 3.7%.
Other taxes Asset tax, Social contributions
Government fee No
Stamp duty 1%

Accounts

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Requirement to file accounts Publicly accessible accounts Audit required Requirement to file Annual Return Publicly accessible Annual Return
Yes No No No No
Requirement to prepare accounts Yes
Double tax treaties network 21
Tax Exchange Information Agreement network 28
OECD member Yes
Offshore/onshore status according to the RF laws Yes

GENERAL INFORMATION

General Info

The Principality of Liechtenstein is a small country in Central Europe, bordered by Switzerland to the west and south and by Austria to the east and north.
Total area of Liechtenstein is 160.475 sq. km. Population of Liechtenstein is 37.009 people (2013). According to the census of 2000, most of the population is Liechtensteiners (65.6%), the other ethnic groups include Italians, Swiss and Austrian.
The capital of Liechtenstein is Vaduz.
The official language of Liechtenstein is German.
The official currency is Swiss franc. 1 USD is equal to 0.88 CHF.
The climate of Liechtenstein is сontinental; cold, cloudy winters with frequent snow or rain; cool to moderately warm, cloudy, humid summers; avg. maximum temperature (July) +27°; avg. minimum temperature (January) +13°.
Time difference with Moscow is -2 hours.
Literacy rate is 100%.
Calling code of Liechtenstein is +423.

History

At one time, the territory of Liechtenstein was part of the ancient Roman province of Raetia. For centuries this territory, geographically removed from European strategic interests, had little impact on European history. Prior to the reign of its current dynasty, the region was enfeoffed to a line of the counts of Hohenems.
The Liechtenstein dynasty, from which the principality takes its name, comes from Castle Liechtenstein in Lower Austria, which the family possessed from at least 1140 until the 13th century, and from 1807 onward. Through the centuries, the dynasty acquired vast tracts of land, predominantly in Moravia, Lower Austria, Silesia, and Styria, though these territories were all held in fief under other more senior feudal lords, particularly under various lines of the Habsburg family, whom several Liechtenstein princes served as close advisers. Thus, without any territory held directly under the Imperial throne, the Liechtenstein dynasty was unable to meet a primary requirement to qualify for a seat in the Imperial diet (parliament), the Reichstag.
The family yearned for the added power a seat in the Imperial government would bring and therefore sought to acquire lands that would be unmittelbar, or held without any feudal personage other than the Holy Roman Emperor having rights on the land. After some time, the family was able to arrange the purchase of the minuscule Herrschaft ("Lordship") of Schellenberg and county of Vaduz (in 1699 and 1712 respectively) from the Hohenems. Tiny Schellenberg and Vaduz had exactly the political status required: no feudal lord other than their comital sovereign and the suzerain Emperor.
On 23 January 1719, after the lands had been purchased, Charles VI, Holy Roman Emperor, decreed that Vaduz and Schellenberg were united and elevated the newly formed territory to the dignity of Fürstentum (principality) with the name "Liechtenstein". It was on this date that Liechtenstein became a sovereign member state of the Holy Roman Empire.
Liechtenstein was part of the German Confederation from 1815 to 1866 which was presided over by the Emperor of Austria. In 1860 the Liechtenstein became hereditary members of the upper chamber of the Austrian Parliament. In 1866 the principality became independant. Until the end of World War I, it was closely tied to Austria, but the economic devastation caused by that conflict forced Liechtenstein to enter into a customs and monetary union with Switzerland. During World War II Liechtenstein remained neutral. In 1990 Liechtenstein joined UN, in 1991 – European economic zone, and in 2011 – Shengen zone.

Government Type

Liechtenstein is a constitutional monarchy.
The head of state is the Prince, who represents Liechtenstein in its international relations (although Switzerland has taken responsibility for much of Liechtenstein's diplomatic relations). The Prince may veto laws adopted by parliament. The Prince can call referenda, propose new legislation, and dissolve parliament, although dissolution of parliament may be subject to a referendum.
Executive power is vested in a collegiate government comprising the head of government (prime minister) and four government councilors (ministers). The head of government and the other ministers are appointed by the Prince upon the proposal and concurrence of parliament. The constitution stipulates that at least two members of the government be chosen from each of the two regions. The members of the government are collectively and individually responsible to parliament; parliament may ask the Prince to remove an individual minister or the entire government.
Legislative power is vested in the unicameral Landtag made up of 25 members elected for maximum four-year terms according to a proportional representation formula. Fifteen members are elected from the "Oberland" (Upper Country or region) and ten members are elected from the "Unterland" (Lower Country or region). Parliament proposes and approves a government, which is formally appointed by the Prince.
Judiciary power is vested in the Regional Court at Vaduz, the Princely High Court of Appeal at Vaduz, the Princely Supreme Court, the Administrative Court, and the State Court.

Economy

Despite its limited natural resources, Liechtenstein is one of the few countries in the world with more registered companies than citizens; it has developed a prosperous, highly industrialized free-enterprise economy and boasts a financial service sector as well as a living standard which compares favorably with those of the urban areas of Liechtenstein's large European neighbours.
Very low business taxes (lowest in Europe after Andorra's 10% maximum tax rate) - the corporate tax rate is a flat 12.5% - as well as easy Rules of Incorporation have induced about 73,700 holding (or so-called 'letter box') companies to establish registered offices in Liechtenstein. This provides about 30% of Liechtenstein's state revenue. Liechtenstein also generates revenue from Stiftungen ("foundations"), which are financial entities created to hide the true owner of nonresident foreigners' financial holdings. The foundation is registered in the name of a Liechtensteiner, often a lawyer.
Recently, Liechtenstein has displayed stronger determination to prosecute international money-launderers and has worked to promote the country's image as a legitimate finance center.
Liechtenstein participates in a customs union with Switzerland and employs the Swiss franc as national currency. The country imports about 85% of its energy. Liechtenstein has been a member of the European Economic Area since May 1995. The government is working to harmonize its economic policies with those of an integrated Europe.
Liechtenstein is a large producer of ceramics and is the world's largest producer of sausage casings and false teeth. Other industries include electronics, textiles, precision instruments, metal manufacturing, power tools, anchor bolts, calculators, pharmaceuticals, and food products. Liechtenstein produces wheat, barley, corn, potatoes, dairy products, livestock, and wine. Tourism accounts for a large portion of the country's economy.

CORPORATE INFORMATION

Legal System

Liechtenstein is a civil law jurisdiction, whose national law was formed under the influence of Swiss and Austrian law with local adaptations. Civil and criminal codes are of Austrian origin, whereas Swiss law was adopted to regulate commerce. Liechtenstein accepts compulsory International Court of Justice jurisdiction with reservations.

Types of Entity

The principal forms of business organization in Liechtenstein are:
  • Sole Proprietorship,
  • General Partnership (Kollektivgesellschaft),
  • Limited Partnership (Kommanditgesellschaft),
  • Cooperative Society (Genossenschaft),
  • Private limited company (Gesellschaft mit beschränkter Haftung, GmbH),
  • Company limited by shares (Aktiengesellschaft, AG),
  • Establishment (Anstalt),
  • Joint Venture (Einfache Gesellschaft),
  • Branch Office,
  • Trust Company (registriertes Treuunternehmen/Trust reg.),
  • Trust (Treuhänderschaft),
  • Foundation (Stiftung).

Along with the company limited by shares, another common structure which is specific to Liechtenstein is Establishment (Anstalt).

Establishment

Establishment (Anstalt) is a type of entity of private law of Liechtenstein which can only be found in this country. Establishment has unlimited legal capacity and may be incorporated for long-term commercial and other purposes.
Establishment is a flexible structure, which can be used as a foundation or instead of it, or like company limited by shares as a commercial enterprise or a holding company.

ESTABLISHMENT REGISTRATION

Company Name

There is a range of requirements to the name of an Establishment in Liechtenstein:
  • The name of the Anstalt must contain the word ‘Anstalt’ or its foreign language equivalent (English: ‘Establishment’, French: ‘Etablissement’, Italian: ‘Stabilimento’).
  • A name should not be identical to or too similar to a name already appearing on the register of companies.
  • A name that may imply government patronage cannot be used.
  • The company name can be in any language using Latin or German characters, but the Registry may require a German translation. Names in Cyrillic alphabet are not allowed;
  • Special permission must be obtained if national or international state or place names are planned to be used in the company name: Liechtenstein, State, Country, Municipality, Principality.
  • The following names, their derivatives or foreign language equivalents require consent or a license: Bank, Building Society, Savings, Insurance, Assurance, Reinsurance, Fund Management, Investment Fund, Red Cross, as well as any other names that may suggest association with the banking or insurance business.

Establishment Registration

The following steps are required to incorporate a company in Liechtenstein:
  1. Check availability of a company name : an enquiry must be made to the Office of Land and Trade Registry of the Liechtenstein National Administration that keeps the register of companies to make sure the proposed name is not used by any other company. After registration, the company name is protected (exclusiveness of the registered name).
  2. Apply for a trade license: the submission of a trade license application to the Office of Economic Affairs is required if the company will be commercially active in Liechtenstein.
  3. Draw up the Aricles of Association and founding documents:
  4. Register with tax authorities: obtain a certificate of tax compliance from the tax authority (and if applicable, the application for a VAT number).
  5. Open a company bank account
  6. Pay in company capital
  7. Obtain the statement of acceptance of the auditor(s), the statement of independence and the notification of the auditor responsible
  8. Obtain acceptance and certified statement of the company signatories (particularly the managing director and the board of directors)
  9. Apply for registration at Liechtenstein's Commercial Register : to register a company in Liechtenstein's Commercial Register, the following documents require to be submitted: 1) A certified registration application; 2) Certificate of tax compliance from Liechtenstein's tax authority; 3) Proof of the company's capital (bank confirmation of the capital deposit); 4) The acceptance- and statement of all who may sign on behalf of the company; 5) Acceptance- and statement of independence of the auditor(s); 6) Certified Articles of Association and/or the recorded founding documents; 7) Trade license warranty (if required).

In general, the formation of a new Establishment in Liechtenstein takes 3-5 days. It is possible to buy a shelf company of this type, though it should be noted that owing to the costs associated with incorporation and the paid up share capital requirements, shelf companies are not widely available.

Restrictions on Activities

There are a number of restrictions on the activities of Liechtenstein bodies corporate and trusts. They cannot undertake the business of banking, insurance, assurance, reinsurance, fund management, collective investment schemes or any other activity that would suggest an association with the banking or finance industries, unless a special license is obtained.

Local Registered Office and Registered Agent

Establishments must maintain a registered office in Liechtenstein and keep there the details of the directors, officers and shareholders. Every Anstalt must have a legal representative or agent for service which must be a natural person, resident in Liechtenstein or a Liechtenstein corporate entity. The agent for service represents the company before the authorities and his/its address is regarded as the official postal address of the company. According to the law he may accept the service of declarations and any other notice or information of whatever nature and kind whatsoever. In the absence of a specific power of attorney or authorization, the agent for service has no further competences. The agent for service has no management authority.

Seal

There are no statutory requirements for a Liechtenstein Anstalt to have a seal.

Bank Account

Liechtenstein Anstalts may open accounts with banks both within and outside Liechtenstein.

Redomicile

The redomiciliation of Anstalts to or from Liechtenstein is permitted.

COMPANY STRUCTURE

Directors

The Anstalt is managed by the board of directors. The board of directors are normally appointed by the founder for a term of three years, but may be appointed for lesser or longer terms of office. The board may consist of one or more natural or legal persons. At least one director, authorized to represent and conduct business for the Anstalt must have his registered office in the country. This member must also be authorized to practice as a lawyer, trustee, or auditor, or have other qualifications recognized by the government. There are no other requirements as to the nationality or residence of the remaining members of the board. Director’s details are disclosed to the local agent and his name, addresses, and signatory authorities are registered in the Public Register and appear on the public file. Board meetings of the company may take place both in and outside Liechtenstein.

Secretary

Anstalt is not required to appoint a company secretary.

Auditor

The law requires the appointment of an auditor, if Anstalt carries on business, or if its objects permit it to do so. If the objects of Anstalt are limited to the management of assets, holding of participations and other rights, then it is not necessary to appoint an auditor.

Founders

The Anstalt can be formed by one founder, individual or corporate of any nationality or residence. Founder’ details are disclosed to the local agent but do not appear on the public file. Annual meetings of founders are not required unless otherwise provided for in the articles.

Beneficiaries

The beneficiaries of an Establishment in Liechtenstein may be natural or legal persons. The Establishment’s founder designates the beneficiaries. The beneficiaries must be specifically named in the Establishment‘s articles of association or the by-laws. Where it is not clear who the beneficiaries are, the owner of the founding rights will be deemed to be the beneficiary. Where the beneficiaries are specified in the Establishment‘s by-laws, their names are not registered in the Commercial Register and the beneficiaries accordingly remain anonymous and must be disclosed as part of the obligatory due diligence to the local agent and local bank where the company opens an account for payment of share capital, as well as to the auditor (if one is appointed), and can only be disclosed by them in the cases stipulated by law and following statutory procedure. In contrast, anonymity for the beneficiaries does not exist if the beneficiaries are specified in the Establishment‘s articles of association.

Share capital and Shares

The capital of Anstalt is normally denominated in Swiss francs (CHF), but can also be denominated in USD or EUR. Anstalt must have a minimum capital of CHF 30,000 or USD 30,000 or EUR 30,000, which must be fully paid in. A certification by a Liechtenstein or Swiss bank that the capital has been paid in must be presented to the Registry officials along with the other constitutive documents. The capital must remain in the incorporation account at the bank until Anstalt is registered. It is then available to the Anstalt to be applied according to the objects.
Usually the authorized capital is CHF 30,000.
The capital may be segmented into shares which may or may not have the character of a security. Where the capital is to be segmented into shares, the minimum sum to be contributed is 50,000 Swiss Francs or Euros or US. Dollars.

LIQUIDATION

Liquidation

The right to liquidate is that of the founder or the holder of the founder’s rights. In a resolution to liquidate, the founder shall designate one or several liquidator(s) and establish his (their) authority. The resolution to liquidate will be entered in the Public Register, and notice to creditors will be published in the official publication of Liechtenstein. The Anstalt in liquidation retains its identity as a legal person and adds the words ‘in liquidation’ to its name. In the liquidation process the liquidators must first prepare a liquidation balance sheet. Thereafter they must proceed to call in receivables, realize the assets and wind-up current business. The liabilities of the Anstalt are to be discharged. Fixed assets are to be liquidated and uncalled capital called in to the extent that the same is legally required. Known creditors may be paid either by depositing funds with the court, or by direct payment. The liquidation surplus is distributed to the beneficiaries. An Anstalt in liquidation must nevertheless prepare annual financial statements. At any time during the liquidation process the founder may rescind his decision to liquidate and carry on with business as usual. Generally speaking after the expiry of six months calculated from the notice to the creditors, the Anstalt may be struck off the registry. Prior thereto the supreme executive organ of the Anstalt must approve the final financial statements and exonerate the liquidators. Any liquidation proceeds are paid to the beneficiaries designated by the holder of the founder's rights. All records of a liquidated Anstalt must be preserved for ten years.

TAXATION

Personal Income Tax

Liechtenstein tax residents pay tax on their worldwide income and non-residents on income from sources in Liechtenstein.
Income tax is paid at the national and municipal level.
Tax rates at the national level are different for single individuals, married couples, and single parents with children.
For a taxpayer who is single, tax rates are:
  • Income below CHF 15,000 – 0%
  • Income from CHF 15,000 to 20,000 – 1%
  • Income from CHF 20,000 to 40,000 – 3%
  • Income from CHF 40,000 to 70,000 – 4%
  • Income from CHF 70,000 to 100,000 – 5%
  • Income from CHF 100,000 to 130,000 – 6%
  • Income from CHF 130,000 to 160,000 – 6.5%
  • Income from CHF 160,000 to 200,000 – 7%
  • Income over CHF 200,000 – 8%.

Municipal income tax is calculated as a percentage (from 150% to 250%) of the national tax.
Thus, the total national and municipal tax rate varies from 2.5% to 22.4%, depending on the level of income and place of residence.
For people who have moved to Liechtenstein, it is possible to apply a tax calculated on the basis of their living costs. In this case, one cannot work in Liechtenstein and must meet some other conditions.
The profit from the sale of shares in local and foreign companies is tax exempt. The exemption does not apply to shares that constitute a commercial asset if more than 50% of the foreign company's income is passive income and the company is taxed at low rates.
Dividend income is tax exempt. If dividends are paid by a company with at least 25% participation, the shares of which constitute a commercial asset of the taxpayer, such dividends should not be deducted by the paying party for tax purposes (this requirement does not apply if the shares are a personal asset of an individual). The exemption does not apply to dividends on shares of a foreign company if more than 50% of its income consists of passive income and the company is taxed at low rates.

Corporate Income Tax

Companies pay corporate income tax at the rate of 12.5%.
There is a minimum tax of CHF 1,800 which can be credited against the corporate income tax.
The profit from the sale of shares is tax exempt. The exemption does not apply if more than 50% of the income of the foreign company whose shares are being sold is passive income and the company is taxed at low rates.
Dividend income is tax exempt. If the income comes from a company with at least 25% participation, such dividends should not be deducted by the paying party for corporate income tax purposes. The exemption does not apply if more than 50% of the income of the foreign company distributing the dividend consists of passive income and the company is taxed at low rates.

CFC Rules

Liechtenstein has no CFC rules as such.
However, it should be noted that the use of structures aimed at tax evasion may have negative tax consequences.

Withholding Tax

Liechtenstein does not levy withholding tax.

VAT

The standard VAT rate is 7.7%.
The VAT rates of 2.5% and 3.7% apply to some goods and services.

Wealth Tax

Movable and immovable assets are subject to tax.
Generally, the tax base is a percentage (in 2021, 4%) of the market value of the assets. Such notional income is subject to ordinary income tax.
When transferring assets to a non-taxable entity or under circumstances that make the assets no longer subject to wealth tax, the transferor pays a 3.5% tax on the value of the assets (together with municipal tax, the rate can be up to 10.5%).
There is no inheritance or gift tax.

Social Security Contributions

The following social security contributions are paid:
  • Old age insurance, disability insurance – 9.991% (5.291% by the employer and 4.7% by the employee)
  • Family compensation fund – 1.9% (by the employer)
  • Unemployment insurance – 1% (by the employer and employee in equal shares)
  • Occupational accident insurance – about 0.1% (by the employer)
  • Pension insurance – contributions depend on the pension plan.

Stamp Duty

Stamp duty is payable when a company is formed or when its capital is increased.
The rate is 1% of the nominal and additional capital. The first CHF 1 million is exempt.
There are also other cases where tax is charged at the establishment of legal entities.
The tax on securities transactions involving a dealer is 0.15% for Swiss and Liechtenstein securities and 0.3% for foreign securities.

Double Tax Agreements

Liechtenstein has exchange of information relationships with 40 jurisdictions through:
  • 21 DTA: Andorra, Austria, Czech Republic, Georgia, Germany, Guernsey, Hong Kong, Hungary, Iceland, Jersey, Lithuania, Luxembourg, Malta, Monaco, Netherlands, San Marino, Singapore, Switzerland, United Arab Emirates, United Kingdom, and Uruguay.
  • 28 TIEA: Andorra, Antigua and Barbuda, Australia, Belgium, Canada, China, Denmark, Faroe Islands, Finland, France, Germany, Greenland, Guernsey, Iceland, India, Ireland, Italy, Japan, Liechtenstein, Mexico, Monaco, Netherlands, Norway, Saint Kitts and Nevis, Saint Vincent and the Grenadines, South Africa, Sweden, United Kingdom, and the United States.

Exchange Control

  • Liechtenstein has no exchange control.
  • ACCOUNTS

  • Financial Statements

  • If the Anstalt carries on business, or if its objects as laid down in the articles permit the same, then fully audited financial statements (comprising the balance sheet, profit-and-loss account and if necessary the annex) must be submitted annually to the Liechtenstein tax authorities. The statements are not required to be published. If the objects of the Anstalt are limited to the management of assets, holding of participations and other rights, then it is not necessary to appoint an auditor. In this case, the Anstalt is obligated to make a Declaration concerning its net worth. The Board member of the Anstalt resident in Liechtenstein must give a written Declaration to the Public Register within six months after the close of the financial year. This Declaration must merely confirm that a list of assets has been drawn up at the end of the previous financial year (without revealing information concerning the actual net worth) and that the Anstalt has not carried out any commercial business during the previous year. All records of an Anstalt must be preserved for ten years. Accounting books and records, with the exception of the financial statements, may be stored in microfilm or similar form.
  • Annual Return

  • Generally speaking, Annual Return is a short review on the current state of the company, which is prepared by the company secretary annually. As a rule it includes the following information:
  • Incorporation information (registration date, registered address);
  • Information about directors and their resignation;
  • Information about secretaries and their resignation;
  • Information about registered capital, nominal value of shares and amount of issued shares;
  • Information about shareholders and share transfer.

  • Liechtenstein establishments are not required to prepare Annual Return.

    Tax Returns

    The tax year is the same as the financial year of the company.
    The tax return must be filed by 1 July of the calendar year following the tax year-end.
    Based on the company’s tax return, the tax authorities issue a tax assessment.
    The tax must be paid within 30 days of receiving the tax assessment.

    SPECIAL LEGAL ENTITIES

    Trusts

    Liechtenstein introduced the Anglo-Saxon concept of trust into its legislation in 1926 and since then has been the only continental European country to recognize the trust relationship. The Anglo-Saxon trust legislation was not adopted blindly, but with modifications. For example, in Liechtenstein trusts there is no bar against accumulation of income, nor against perpetuities.
    Trusts may be set up under foreign law, but may not have more favorable treatment than would apply under Liechtenstein law.

    Purpose of Trust
    A Trust in Liechtenstein may be formed for commercial or non-commercial purposes insofar as the said purposes are not illegal or immoral.
    A Trust in Liechtenstein is suited to the long-term protection of assets, family assets or to estate planning.

    Trust Name
    Trust name can be freely chosen in any language. However, it is required to check the name in he Commercial registry for availability. National and international names of countries and geographic locations cannot be used in a trust name.
    A word “Treuhänderschaft” (Trust) in full form should be added to the name.

    Trust Formation
    The law requires the trust to be set up by a written agreement (deed of trust) between the settlor and trustee(s) or through a unilateral Trust declaration and its acceptance. The deed of trust may be in any language and should include provisions describing the nature of the trust property, conditions regarding beneficiaries, and ultimate disposition of the trust property. The trust deed may provide for the appointment by the settlor of a third party to act as protector and to assist the trustees either in an advisory capacity or with joint power of decision.
    Any trust with a duration of more than 12 months must within 12 months of its establishments be either registered with the Public Registry (by making available to the Registry a document containing the name or description of the trust, date of establishment, duration, and full names and residence of trustees) or get the original deed of trust or its certified copy deposited with the Public Registry.
    A registration fee of CHF 200 is payable on registration.
    Any changes to the particulars of the trust must also be recorded at the Public Registry. The trust deed or details of the trust are not available for public inspection, so confidentiality is preserved.

    Minimum Trust Property
    No minimum requirement of Trust property exists for the formation of a Trust in Liechtenstein. It can be 1000 CHF.

    Trust Organization
    The settlor of a Trust in Liechtenstein is the founder of the Trust and it is he who provides the Trust property. The settlor of a Trust in Liechtenstein may be a legal or natural person. As is the case with an English law Trust following its formation, the settlor of a Trust in Liechtenstein enjoys no rights as to the administration or control of the Trust. Accordingly, the settlor of a Trust in Liechtenstein may only exercise those rights which are expressly stated in the Trust deed.
    The administration of a Trust in Liechtenstein obligates the Trustees to give a comprehensive account of their work as Trustees. Therein, it is required that the Trust property be held by the Trustees in separation from their personal assets. Where the Trust property of a Trust in Liechtenstein perishes or where the Trust property is lost by the Trustees, the beneficiary/beneficiaries may demand under certain conditions that the Trust property which has been lost be replaced by an equivalent amount of assets.
    Auditors may be appointed by a Trust in Liechtenstein to ensure that the obligations set out in its Trust deed are complied with.
    The settlor of a Trust in Liechtenstein designates the beneficiary/beneficiaries of the Trust. The beneficiary/beneficiaries may be the settlor himself or any other natural or legal person. The beneficiary/beneficiaries of a Trust in Liechtenstein exercises only a passive role in the management of the Trust.

    Accounts
    It is not required to file annual accounts to Liechtenstein Tax administration.
    Taxation of Trust
    A Trust in Liechtenstein is required to pay annually 1,200 Swiss Francs in corporate income tax. Trusts are exempt from filing tax return.

    Liquidation
    Trust Deed can freely set the reasons or conditions for dissolution of trust.
    The liquidation of a Trust in Liechtenstein may take place at any time. There exists no specified time limit which must be adhered to.

    Foundations

    A Foundation (Stiftung) in Liechtenstein is an autonomous special-purpose Fund that has its own legal personality. The said special-purpose Fund is separate from the assets of its founder and forms the assets of the Foundation from then on. The assets of a Foundation in Liechtenstein are wholly liable for the liabilities of the Foundation. A Foundation in Liechtenstein may be formed as a private-benefit Foundation in the form of a pure family Foundation, as a charitable Foundation, as a church Foundation as well as a maintenance Foundation. In contrast to a corporation under private law, a Foundation in Liechtenstein has no members, partners or shareholders.

    Purpose of Foundation
    A Foundation in Liechtenstein may be formed for the carrying on of charitable or private purposes. Notwithstanding this, a charitable Foundation in Liechtenstein may only carry on commercial activities if they either lead directly to the achievement of its charitable purposes or they are expressly allowed for by law. In contrast thereto, a Foundation in Liechtenstein which is formed for private purposes may carry on commercial activities if the said activities are necessary for the proper investment and management of its assets.

    Foundation Name
    Foundation name can be freely chosen in any language. However, it is required to check the name in he Commercial registry for availability. National and international names of countries and geographic locations cannot be used in a trust name.
    A word “Stiftung” (Foundation) in full form should be added to the name.

    Formation of Foundation
    A Foundation in Liechtenstein is formed through an officially recorded Foundation declaration. The said declaration is not publicly available. Foundations in Liechtenstein that are carrying on commercial activities must be registered in the Commercial Register. The Commercial Register is a public register. Charitable Foundations in Liechtenstein which are not carrying on commercial activities must similarly be registered in the Commercial Register. In contrast thereto, private-benefit Foundations in Liechtenstein which are not carrying on commercial activities are only required to lodge its Foundation document with the court.

    Minimum Capital
    For the formation of a Foundation in Liechtenstein, a minimum 30,000 Swiss Francs or Euros or US. Dollars must be contributed to its capital.

    Organization of Foundation
    The founder of a Foundation in Liechtenstein determines its purpose and its beneficiaries. The said rights may be exercised by a trustee vis-à-vis third parties. However, a trustee is not authorized to transfer or bequeath the founder‘s rights. Furthermore, the founder of a Foundation in Liechtenstein may reserve the right to revoke the Foundation or to amend the Foundation document.
    The Foundation council is the administrative body of a Foundation in Liechtenstein. It is required that at least one of its members has his law office address in Liechtenstein and that he possesses certain professional qualifications.
    The address of the person registered as a
    Foundation's representative will be the Foundation’s official address. The representative will also act as the contact person between the Foundation and the authorities.
    The rights of the beneficiaries of a Foundation in Liechtenstein shall be regulated by its articles of association and by-laws. The said rights may be restricted and conditions may be attached. Moreover, the founder of a Foundation in Liechtenstein is entitled to designate himself as its beneficiary. A distinction requires to be made between the different classes of beneficiaries which include: prospective beneficiaries, discretionary beneficiaries and the ultimate beneficiaries. Following the death of a beneficiary of a Foundation in Lichtenstein, where this is explicitly provided for, the next specified person takes the deceased beneficiary‘s place and not the deceased beneficiary‘s heir (or heirs).

    Accounts
    All the documents of unregistered Foundation related to its activities, must always be accessible in order to determine Foundation’s assets.
    In case Foundations registered in Commercial Register are carrying on commercial activities in order to achieve their non-commercial purposes, they are obliged to keep accounting record and file audited balance sheet with the Tax administration within 6 months after the end of the accounting year.

    Taxation of Foundation
    A Foundation in Liechtenstein is required to pay annually corporate income tax rate at a single rate of 12.5% on its taxable income. Therein, a Foundation in Liechtenstein must pay annually at least 1,200 Swiss Francs in corporate income tax. Due to the interest deduction on equity capital, a deduction of 4% is to be deducted when calculating the tax liability of a Foundation in Liechtenstein. Furthermore, a Foundation in Liechtenstein which qualifies as a Private Asset Structure (PAS) in accordance with Liechtenstein‘s tax law of January 1st, 2011 shall always only pay corporate income tax of 1,200 Swiss Francs each year.
    No tax requires to be paid by a Foundation in Liechtenstein on the dedicating of assets to the Foundation or on the allocation of the Foundation assets to its beneficiaries. Furthermore, following Liechtenstein‘s tax reforms, the Capital and Coupon taxes have been abolished. The estate-, inheritance- and capital transfer taxes are no longer required to be paid by natural persons.

    Dissolution of Foundation
    A Foundation in Liechtenstein may be liquidated by declaration of its invalidity or dissolution. Foundation can be declared invalid only in cases stipulated by law and in compliance with the provisions of the articles of association. Foundation can be dissolved in the following cases:
    • winding-up of Foundation’s assets;
    • resolution refusing the wingding-up due to the deficit of assets for reimbursement of costs of the winding-up;
    • court order about dissolution;
    • resolution by Foundation council.

    Foundation council is obliged to pass a resolution on Foundation’s dissolution in the following cases:
    • If it got admissible requirement from the founder about invalidity of the Foundation, if the purpose of the Foundation was achieved or became unachievable, e.g. due to the lack of the assets;
    • If the term of activity indicated in the Articles of Association expired;
    • There are other conditions stipulated by the Articles.

    Preparation for the winding-up, carried out by the Foundation council and Commercial register, lasts 5 days.
    The same conditions apply to the lodged foundations. In this case the liquidation procedure until striking off the Register lasts 6 months, as it is required to block the procedure for 6 months after the third notification of the creditors. Upon approval of the Register it is possible to reduce the time limit and allocate the assets before the expiration of 6-month period, provided the creditors’ interests are not influenced. The procedure of liquidation ends by striking the Foundation off the Register.

    Family Foundation
    A private-benefit Foundation in Liechtenstein may be formed as a “pure” family Foundation for the management of family and commercial assets internationally. Furthermore, the said Foundation may be formed to ensure the long-term safeguarding of the assets, particularly family structures which are internationally dispersed, thereby optimizing the allocation of the assets across borders.
    A personal-benefit (family-) Foundation in Liechtenstein may be set up in such a way that founder‘s relatives shall be well provided for after his death whilst at the same time as compelling the said relatives to comply with certain conditions. A further advantage of a private-benefit Foundation in Liechtenstein being used to transfer the founder‘s assets to his offspring -instead of by way of a gift or a legacy- is that it avoids a fragmentation of the family assets.
    A private-benefit Foundation in Liechtenstein is not subject to external supervision and is not required to be registered in the Commercial Register - a public register. Furthermore, it is not mandatory that the Foundation document be lodged with the court. Instead it is sufficient that a private-benefit Foundation in Liechtenstein only submits a notification of its formation to the Registry of Deeds and Public Registry office. Moreover, there is no requirement for a private-benefit Foundation in Liechtenstein to disclose the identities of its beneficiaries to the Liechtenstein authorities.

    Trust vs. Foundation

    A short overview of the main differences between a trust and a foundation is set out below:
    Trust Foundation
    Legal form/ asset status Segregated assets owned by the trustee, no legal personality Legal entity with its own assets and legal personality
    Bodies/functions Trustee, possibly a protector (who are not bodies in the company­law sense) Foundation council, possibly protector, other bodies possible
    Commercial activities Permitted to engage in commercial and non­commercial activities Only permitted to engage in commercial activities to achieve non­commercial goals
    Capital/ minimum capital No minimum capital required, often small initial capital stipulated (e.g. CHF 1‘000) Minimum capital of CHF 30‘000 (or EUR or USD 30‘000)
    Registration Registration (not necessary
for legal validity, minimal information required) or deposit (trust deed) Deposit of the notification of formation or registration (necessary for legal validity)
    Beneficiaries Defined in the trust deed itself or in attachments Usually defined in a supplementary foundation deed

    The fact that trust deeds are usually drafted in greater detail than foundation documents and specify all of the rights and duties of the settlor, trustee and beneficiaries is attributable to their origins in the common law concept of trusts, which is based on the decisions of the courts rather than on statute. Foundations which are rooted in the civil law tradition are always governed by statutory provisions and therefore do not require such detailed private law provisions. Being a civil law jurisdiction, Liechtenstein has codified its trust law. However, Liechtenstein trust deeds are nonetheless still drafted in detail as this leaves open the option of a subsequent transfer of the trust to a common law jurisdiction (this can be achieved easily through the appropriate amendment of the choice of law clause in the trust deed and the corresponding change in the identity of the trustee). Moreover, the adaptation to the Anglo­Saxon style of trust deed helps to increase the recognition of a trust abroad in cases with international aspects. For this reason, Liechtenstein trust deeds often contain elements of Anglo­Saxon trust law although such inclusions would not be necessary under Liechtenstein law (e.g. perpetuity period). In addition, trust deeds are drafted in such detail so that it is possible to adapt Liechtenstein trust law, which is dispositive in many respects, to the needs of the client. Due to the liberal regulation of trust law, this can be done without any difficulty.
    Following the reform of foundation law in 2009 and the reform of tax law in 2010, the differences between the two Liechtenstein legal forms – trust and foundation – have increased. Trusts have acquired clear advantages. An obvious benefit is the relatively high degree of flexibility and operating freedom they allow (both for the settlor and for the trustee) since they are based on dispositive law. These have been significantly curtailed in the case of foundations since the reform.
    A significant difference between trusts and foundations is that a foundation is much less flexible with regard to its purpose. One speaks of foundations being subject to the principle of rigidity. This underlying principle requires the founder to stipulate the foundation’s purpose (in particular, the rules designating beneficiaries) at the time of its establishment in a manner that is unalterable. The foundation’s purpose may only be altered by the founder during his lifetime provided that he has reserved the right to do so in the foundation deed. In addition, this right is restricted to founders who are natural persons. It is possible to grant the settlor of a trust comparable rights. However, in the case of a trust, the additional option exists of granting the trustee a broad and far-reaching discretion to alter the terms of the trust without the settlor’s consent although the exercise of such discretion is often contingent upon the protector’s consent. The principle of rigidity is not known to Liechtenstein trust law, and trusts are therefore a dynamic instrument for asset structuring.
    Trusts are not subject to corporate income tax since they are not legal persons; however, they have to pay the minimum corporate income tax thus affords trusts a clear advantage over foundations and other asset structures with legal personality as far as taxation is concerned. While it is necessary to structure and establish legal persons (foundations, establishments, etc.) as what are known as private asset structures in order to obtain exemption from the duty to submit a tax return and limit taxation to the minimum amount of corporate income tax, the same is not necessary in respect of trusts. In the case of a trust, the trustee simply pays the minimum corporate income tax of CHF 1,200 annually, irrespective of the type of trust property or its value, and does not have to satisfy the requirements of a PVS.

    International law relations

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    Party to the Hague Convention (Apostille) Legal system Double tax treaties network OECD member Offshore/onshore status according to the RF laws
    Yes civil law 21 Yes Yes

    Public authorities and legal acts

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    List of laws and regulations
    Act name Scope of law
    Law on Persons and Companies (Personen- und Gesellschaftsrecht) 1926 companies
    Law on Investment Undertakings 2005 investment
    Law on National and Municipal Taxes (Tax Act) 2010 taxation
    Law on Value Added Tax 1995 VAT
    Swiss Federal Law on Stamp Duty 1973 stamp duty
    Tax treaties entered Andorra, Austria, Czech Republic, Georgia, Germany, Guernsey, Hong Kong, Hungary, Iceland, Jersey, Lithuania, Luxembourg, Malta, Monaco, Netherlands, San Marino, Singapore, Switzerland, United Arab Emirates, United Kingdom, and Uruguay
    Tax Exchange Information Agreement (TEIA) Andorra, Antigua and Barbuda, Australia, Belgium, Canada, China, Denmark, Faroe Islands, Finland, France, Germany, Greenland, Guernsey, Iceland, India, Ireland, Italy, Japan, Liechtenstein, Mexico, Monaco, Netherlands, Norway, Saint Kitts and Nevis, Saint Vincent and the Grenadines, South Africa, Sweden, United Kingdom, and the United States
    List of state regulatory authorities
    Liechtenstein Government http://www.liechtenstein.li/index.php?id=54&L=1
    Liechtenstein's National Administration http://www.llv.li/
    Liechtenstein Financial Market Authority http://www.fma-li.li/startseite.html
    Liechtenstein Tourism Board http://www.tourismus.li/
    Liechtenstein Legal Gazette https://www.gesetze.li/
    Office of Economic Affairs http://www.llv.li/#/12481/amt-fur-volkswirtschaft
    Office of Justice – National Administration of Liechtenstein http://www.llv.li/#/11622/amt-fur-justiz
    Tax Authority – National Administration of Liechtenstein http://www.llv.li/#/11610/steuerverwaltung
    The Office of Immigration http://www.llv.li/#/11359/auslander-und-passamt
    Liechtenstein's Chamber of Commerce and Industry http://www.lihk.li/CFDOCS/cmsout/admin/index.cfm?GroupID=20&Lang=2&meID=30&MandID=1
    Liechtenstein Chamber of Lawyers http://www.lirak.li/
    Liechtenstein Investment Fund Association http://www.lafv.li/
    Liechtenstein Bankers Association http://www.bankenverband.li/

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