Liechtenstein Holding Company (AG, GmbH or Anstalt)

Dividends from participations and gains on their sale or liquidation are not part of taxable net income under SteG Art. 48. The limits: a deductible payer at a stake of 25 % or more, a foreign payer both passive and lightly taxed, and the burden of proof on the taxpayer. A minimum tax still applies.

It may. The Liechtenstein exemption binds only Liechtenstein, whose statute looks at the seat or the place of effective management. Your home state applies its own law, which this page does not state, so take the view of your own foreign advisers first. We promise no outcome abroad and no treaty benefit.

The statute names the seat or the place of effective management, and we found no published criteria beyond that, so we promise nothing about substance. Most entities need a licensed trustee or Art. 180a licence holder on the board. What that mandate does for substance is not something we assert.

The law treats holding as a role of the entity, so an AG, GmbH or Anstalt can carry it. We give criteria, not a verdict: minimum capital of CHF 50,000, CHF 10,000 and CHF 30,000, the accounts duty and the formation instrument. You decide with the licensed partner.

A PVS carries on no economic activity and may hold participations only if neither it nor its owners exert actual control, so a control holding is not a PVS. A PVS pays only the minimum tax. The taxpayer confirms the conditions on application and every year, and the Tax Administration decides.

We found no chapter on withholding tax on outbound dividends in the Tax Act text read for this page, so we do not say there is none. The source deductions the Act shows are on employment income and board fees. The Tax Administration publishes the maximum source-tax rates other states may levy.

The Tax Administration overview, state 21 October 2026, lists 32 agreements, 26 of them in force by our count. Where a treaty applies, Liechtenstein gives relief, but a credit for foreign tax is capped at the Liechtenstein tax, so exempt dividends leave nothing to credit.

The minimum income tax is CHF 1,800 a year, credited against the income tax. It is not levied on an entity run exclusively as a commercial business with an average balance-sheet total of at most CHF 500,000 over three years. A holding is by default not commercially run, so it normally pays.

Usually yes. At least one member authorised to manage and represent is an EEA national, a person treated as equal or a legal person, with a Trustee Act or equal Art. 180a licence; some entities are exempt. The Repräsentant is an EEA national resident in Liechtenstein, arranged through the licensed trustee.

Only if your holding is a Liechtenstein unit of a group whose ultimate parent reports annual revenue of at least EUR 750 million in at least two of the four preceding years, under GloBE Act Art. 4(1). A top-up tax at a minimum rate of 15 % then applies. The Act has been in force since 1 January 2024.

Possibly. A buyer inherits the company's history: the old coupon-tax rules still apply to reserves that existed on 1 January 2011. It still needs a qualified board member and Repräsentant, and changes in beneficial owners are reported within 30 days of knowledge; since the 30 July 2026 cyberattack register access is limited, and deadlines that cannot be met are suspended.

An AG or GmbH keeps full annual accounts even without a commercial business, prepared within six months of the year end. An Anstalt without a commercial business keeps records proportionate to its assets. Tax return documents are in German, and bookkeeping and tax advice for others are reserved activities.

The report is due within 30 days of the register entry, and changes within 30 days of knowledge. Since the 30 July 2026 cyberattack access is limited, identification is in person in Vaduz from 5 October 2026, and deadlines that cannot be met are suspended, with no end date published.

A licensed Liechtenstein trustee, named in your engagement letter, forms the company, files at the register and holds any Art. 180a mandate. These are reserved activities, and exercising them without a licence is an offence. VCS prepares the documents and coordinates the file; it holds no board seat and files nothing.

It acquires legal personality only with the register entry. On capital, two rules stand side by side: PGR Art. 122(2) and the Office of Justice Merkblatt say in full, while Art. 537(2) no. 2 has the deed declare it paid in at least by half. Confirm the rule with the licensed trustee.