Tax Advisory for Liechtenstein Entities

Your tax advisor in Liechtenstein is a licensed trustee; we prepare the file and coordinate every step.

  • Corporate income tax 12.5 %, minimum CHF 1,800
  • Binding rulings on application
  • Return filed electronically, attachments in German or English
  • Licensed trustee advises, VCS coordinates
A town in a valley below the mountains

Who gives tax advice here

Tax advice for third parties is a trustee activity under the Trustee Act (TrHG), Art. 2(d); licensed lawyers also advise their own clients (SPG Art. 3(1)(m)), and tax advice is outside the Trade Act (GewG Art. 3(f)). Practising without the licence is an offence (TrHG Art. 80(1)).

We prepare and coordinate; a licensed Liechtenstein trustee, named in your engagement letter, advises and files. We give no tax advice, submit nothing to the authority and give no legal advice, which the Lawyers Act (RAG) reserves to lawyers. Formation sits on the detailed company registration page, VAT on our VAT registration service.

Green succulent plants on a white background
The tax file, prepared before anyone advises.

What is included

Scoping the structure

We collect the facts on the entity, its owners and its activity; the licensed trustee advises.

Binding-ruling application

We prepare the document list; the licensed trustee or lawyer drafts the questions and the tax-law assessment and submits the application.

Private-asset-structure status

Where an entity may qualify, we prepare the papers. You confirm the conditions; the Tax Administration decides.

Representation papers

A written power of attorney for the trustee, and a named domestic representative where the authority asks a taxpayer with its seat abroad.

Annual return

Who signs, in which language and how it is filed. The figures come from bookkeeping and annual accounts for a Liechtenstein entity.

Pillar Two coordination

Only for groups at or above the EUR 750 million revenue threshold: we coordinate the return and the notification with the licensed partner.

Who does what in a tax engagement

Tax file

One file, five roles

  • VCS

    Collects the facts, prepares the document list, coordinates

  • Licensed trustee

    Advises and acts under the written power of attorney

  • Lawyer

    Party representation

  • Client

    Supplies the facts, signs personally, confirms the private-asset-structure conditions

  • Tax Administration

    Decides on rulings and private-asset-structure status, assesses

Five roles, one tax file.

Where tax questions come up

The questions differ by structure; which taxes apply to a company and its shareholder in Liechtenstein is the overview.

A laptop and a coffee cup on a wooden desk
The annual accounts a return starts from.

Group holding

Participation income, its exemption and its limits, when you are placing the top company of a group in Vaduz.

Foundation or private-asset structure

The status conditions and the yearly confirmation, when you are founding a Stiftung with a foundation council in Vaduz.

Regulated business

The tax file runs next to the FMA approval a regulated business needs in Liechtenstein, which has its own file.

Brand and IP holder

The IP box ended with tax year 2020, so no plan rests on it. See registering a trademark with the Liechtenstein Office of Economic Affairs.

A company bought, not formed

The same scoping questions apply to a company from the list of companies available for transfer this week.

How an engagement runs

Rulings and status decisions have no published processing time; the filing deadline is set every year.

  1. Scoping call and engagement

    We collect the facts and agree the scope; the licensed trustee advises and is named in the engagement letter.

  2. Power of attorney

    You sign a written power of attorney. If your seat is abroad, the Tax Administration may ask you to name a domestic representative.

  3. Binding ruling, where needed

    A written application with the facts, concrete questions and the applicant's own assessment. No processing time is published; the fee is set by ordinance and we print no figure.

  4. Private-asset-structure status

    Where the entity qualifies, you confirm the conditions at the application and every year. An appeal against the decision runs 30 days.

  5. Annual return

    Signed personally with the signed confirmation; return in German, attachments also in English; filed electronically. The deadline is set yearly; an extension is possible on request.

  6. Pillar Two, if it applies

    Only for groups with revenue of at least EUR 750 million: the return and the notification through the LIDES portal.

  7. Assessment

    The Tax Administration assesses. An objection or appeal goes to a lawyer, or to a trustee within its statutory powers.

Seven steps of a tax engagement

  1. Scoping

    Who acts: VCS, licensed trustee

  2. Power of attorney

    Who acts: Client

  3. Binding ruling

    No published time

    Who acts: Licensed trustee or lawyer, Tax Administration

  4. Private-asset-structure status

    No published time; appeal 30 days

    Who acts: Client, Tax Administration

  5. Annual return

    Deadline set yearly

    Who acts: Client, licensed trustee

  6. Pillar Two

    Groups from EUR 750 million only

  7. Assessment

    Who acts: Tax Administration

Seven steps, each with its actor.

Which tax questions does your structure raise first?

Tell us about the entity and its owners; the scoping call sorts the questions for the licensed trustee.

What you supply

  • Facts of the structure: entity, owners, beneficiaries, residence, activity
  • A signed written power of attorney
  • A domestic representative, if your seat is abroad and the authority asks
  • Figures and supporting documents for the return; attachments may be in English
  • The signed confirmation that the return is complete and true
  • The passcode sent with the Tax Administration's information letter
  • For a ruling: the facts in full
  • For private-asset-structure status: your yearly confirmation of the conditions
Scattered gold paper clips on a green background
The signed papers you supply.

Rates, rulings and filing in tables

The rules below come from the 2026 consolidated tax act and ordinance and the Tax Administration's pages.

Corporate income tax and its base

Corporate income tax in Liechtenstein, Tax Act (SteG), 2026 consolidated text

itemrulesource
Rate12.5 % of taxable net incomeSteG Art. 61
Minimum taxCHF 1,800 a yearSteG Art. 62(2)
When the minimum is not chargedsole purpose a commercially run trade, balance-sheet total averaging at most CHF 500,000 over the last three financial yearsSteG Art. 62(3)
Unlimited tax liabilityseat or place of effective management in Liechtenstein, on the entire incomeSteG Art. 44(1), Art. 2(1)(d), (e)
Participation exemptiondividends from participations in legal persons excluded from taxable net incomeSteG Art. 48(1)(e)
Limits of the exemptionholdings of 25 % or more where the payer deducts the payment; foreign payer with mainly passive, lightly taxed income; the taxpayer proves neither appliesSteG Art. 48(3), (7)
Loss carry-forwardreduces positive net income by at most 70 % of taxable net incomeSteG Art. 57(1)
Notional interest deductioncannot create or increase a current loss; standard return 4 %SteG Art. 54(1), Art. 5(1)
Directors' fees to non-residents12 % withheld at source, settling the income taxSteG Art. 63a(3)
IP boxapplied only up to tax year 2020; not a current regimeSteG transitional clause

Sources: Tax Act (SteG); Tax Administration, corporate income tax.

Binding rulings and private-asset-structure status

Binding rulings and private-asset-structure (PVS) status, SteG and SteV

itemrulesource
Binding rulingon application, on a precisely defined fact pattern not yet realisedSteG Art. 93a(1)
Binding commitmentfixes the future treatment of a fact pattern already audited for the pastSteG Art. 93a(2)
What the application containswritten, names the applicant, describes the facts fully, sets out concrete legal questions and the applicant's own tax-law assessmentSteV Art. 38a(1)
Binding effect and its endbinds if later facts do not differ, or differ only insignificantly; ends when the provisions are repealed or amended, or a time limit expiresSteV Art. 38a(2), (3)
Revocationcan be revoked or changed for the future if it proves incorrectSteV Art. 38a(4)
Fee and timeno processing time is published; the fee is set by ordinance and we print no figureSteG Art. 93a(3); SteV Art. 38a(5)
PVS: activity and investorsno economic activity; shares not publicly placed, reserved to private investors; statutes state the PVS restrictionsSteG Art. 64
PVS: solicitation and controlno solicitation of investors, no remuneration; no actual control of held companies' managementSteG Art. 64
PVS: confirmationthe taxpayer confirms the conditions at the application and every year, with the accounting dutySteG Art. 64
PVS: decision and taxthe Tax Administration decides, appeal within 30 days; only the minimum tax, no assessmentSteG Art. 64(5), (8)

Sources: Tax Act (SteG); Tax Ordinance (SteV).

Filing, signature, fines and Pillar Two

Filing, signature, fines and Pillar Two for Liechtenstein legal persons

itemrulesource
Who assessesthe Tax Administration; the municipal tax office takes part only in the assessment of natural personsSteG Art. 101(1)
Representationwritten power of attorney; a taxpayer with its seat abroad may be asked to name a domestic representativeSteG Art. 90, 91(1)
Signature and languagesigned personally; return documents in German (SteG Art. 94(3)), attachments under SteV Art. 41(2) may also be in English (SteV Art. 41(3)); signed confirmation that the return is complete and trueSteG Art. 94(2), (3); SteV Art. 41(2)(f), (3)
Electronic filingcreated and filed electronically, legal persons from tax year 2024; passcode sent with the information letterSteV Art. 42a(1), (2); Tax Administration newsletter 11/2024
Deadlineset every year by the Tax AdministrationSteG Art. 95
Extensionsix months on a reasoned written request within 30 days after the general due date, once the provisional invoice is paid; a further one in specially justified casesSteV Art. 42(1)-(3)
Finesprocedural breach after a reminder up to CHF 1,000, up to CHF 10,000 in serious or repeat cases; evasion normally one times the evaded tax; contributing to evasion up to CHF 10,000, up to CHF 50,000 in serious or repeat casesSteG Art. 135, 137, 139(2)
Pillar Twoconsolidated revenue of at least EUR 750 million in at least two of the four preceding years; return due 15 months after year end, 18 months the first time; tax year 2024 due 30 June 2026; GIR notifications through the LIDES portalGloBE-Gesetz Art. 4(1); Tax Administration GloBE page
Treaties26 of 32 listed agreements in force on 21 October 2026Tax Administration treaty overview

Sources: Tax Act (SteG); Tax Ordinance (SteV); electronic filing newsletter 11/2024; Tax Administration, Pillar Two; treaty overview.

Problems we solve

Rulings cannot be promised

No processing time is published and the fee is set by ordinance, and nothing guarantees a ruling or a status decision. The application states the facts, the questions and the applicant's own assessment.

Old figures in circulation

The IP box applied only up to tax year 2020, and the minimum tax is CHF 1,800.

The exemption has limits

Holdings of 25 % or more where the payer deducts the payment, and foreign payers with mainly passive, lightly taxed income, fall outside it. The taxpayer proves neither applies.

German-language filing for a foreign owner

The return is in German, attachments may also be in English. Add a written power of attorney, a domestic representative if asked, and electronic filing from tax year 2024.

Pillar Two starts at EUR 750 million

The test is consolidated group revenue of at least EUR 750 million in at least two of the four preceding years.

Every file starts with a scoping call

We collect the facts first; the licensed trustee then sets out the tax questions.

Why work with us

Katrin Imhof leads tax, accounting and licensing files and works in German, English and Italian. From our practice: we collect the facts, keep the papers in order and coordinate between the licensed trustee or lawyer and the Tax Administration. The trustee, named in your engagement letter, advises and files.

Frequently asked questions about tax advice in Liechtenstein

Who may give tax advice in Liechtenstein, and who gives it through Vaduz Corporate Solutions?

Tax advice for third parties is a trustee activity under TrHG Art. 2(d). Licensed lawyers also give tax advice to their own clients, and tax advisers fall outside the Trade Act. Through Vaduz Corporate Solutions, the licensed trustee named in your engagement letter advises, while we prepare the file and coordinate.

Does Vaduz Corporate Solutions itself advise on tax or represent me before the Tax Administration?

No. We give no tax advice and submit nothing to the Tax Administration ourselves. The licensed trustee advises and acts under a written power of attorney. Legal advice and representation of a party are reserved to lawyers, and practising a trustee activity without the licence is an offence under TrHG Art. 80(1).

What does a tax advisor in Liechtenstein cost?

Our fees and the partner's fees are on request: send the enquiry form and we answer for your file. The minimum corporate income tax of CHF 1,800 a year is a tax, not a fee. The fee for a binding ruling is left to an ordinance, and we print no figure for it here.

Can tax advice guarantee that my company pays no tax?

No. Corporate income tax is 12.5 % of taxable net income, and a minimum tax of CHF 1,800 a year applies. A private-asset structure pays only the minimum tax and is not assessed. Advice explains the rules and the conditions that apply to your structure; it promises no outcome.

Can a binding ruling or private-asset-structure status be guaranteed?

No. The Tax Administration may give a binding ruling on application, and it decides on private-asset-structure status itself. A ruling can also be revoked or changed for the future if it proves incorrect. We prepare the file carefully, but we promise neither a ruling nor a status decision.

What is the corporate income tax rate and the minimum tax in 2026, and when is the minimum not charged?

The rate is 12.5 % of taxable net income, and the minimum tax is CHF 1,800 a year, under the 2026 consolidated text. The minimum is not charged where the sole purpose is a commercially run trade and the balance-sheet total averaged at most CHF 500,000 over the last three financial years.

What is a private-asset structure (PVS) and what are its conditions?

It is a status under SteG Art. 64 for an entity with no economic activity, shares not publicly placed and reserved to private investors, statutes stating the restrictions, no solicitation or remuneration, and no control of held companies. The taxpayer confirms the conditions every year; the Tax Administration decides, with an appeal within 30 days.

How long does a binding tax ruling take and what does it cost?

No processing time is published, and the statute leaves the fee to an ordinance, so we print neither here. The scoping call is the place to ask what the Tax Administration currently states for your type of question, and the licensed trustee can then plan the application around it.

What must a ruling application contain?

The application is in writing, names the applicant, describes the facts in full and sets out concrete legal questions with the applicant's own tax-law assessment. It concerns a precisely defined fact pattern not yet realised. A binding commitment covers a pattern already audited. The licensed trustee or lawyer drafts the questions.

How long does a ruling stay binding?

A ruling binds the assessment as long as the later facts do not differ from those assumed, or differ only insignificantly. Its effect ends when the provisions it rests on are repealed or amended, or when a time limit expires. It can also be revoked or changed for the future if it proves incorrect.

Are dividends from foreign subsidiaries taxed in Liechtenstein?

Dividends from participations in legal persons are excluded from taxable net income. The exemption has limits: holdings of 25 % or more where the payer deducts the payment, and a foreign payer with mainly passive, lightly taxed income. The taxpayer proves the limits do not apply; whether a holding qualifies is for the licensed trustee.

Does Pillar Two apply to my group?

Only to a group with consolidated annual revenue of at least EUR 750 million in at least two of the four preceding years. The return is due 15 months after year end, or 18 months in the first year, and notifications go through the LIDES portal.

Who signs the annual tax return, in which language, and is it filed online?

The taxpayer signs personally; the return documents are in German and the attachments may also be in English, with a signed confirmation that the return is complete and true. A legal person files electronically from tax year 2024, using the passcode sent with the information letter. Whether the passcode replaces a company's signature is not stated in the ordinance.

Can I get an extension for the tax return?

The deadline is set every year. On a reasoned written request made no later than 30 days after the general due date, the Tax Administration may extend it by six months, once the provisional invoice is paid. A further extension is possible in specially justified cases. The decision is at the authority's discretion.

Who carries out the tax assessment, the Tax Administration or the municipality?

The Tax Administration assesses legal persons. The municipal tax office takes part only in the assessment of taxable natural persons, which is a matter for personal income tax rather than for this page. For a company, every assessment question goes to the Tax Administration.

Start with a scoping call

One call sets out the facts and the questions for the licensed trustee.

+423 210 0003 (Legal department) · Monday to Friday 10:00-18:00 · Rietstrasse 42, 9490 Vaduz · info@company-in-liechtenstein.com