Liechtenstein

0% withholding tax on dividends, interest, and royalties — applies to both resident and non-resident recipients. No WHT friction for cross-border holding structures receiving income from Liechtenstein entities.

0% corporate tax on capital gains from the sale of shares or equity participations. The exemption is built into the CIT statute and is not dependent on a double tax treaty.

12.5% flat corporate income tax — below Germany (approx. 30% combined federal + local), Austria (23%), the Netherlands (25.8%), and comparable to Ireland (12.5%). Participation exemption applies on dividends from qualifying subsidiaries (≥10% stake or CHF 1 million or more).

Notional Interest Deduction (NID) at 4% of equity capital — companies deduct a notional return on equity from taxable income before applying CIT, reducing the effective rate below 12.5% for equity-financed holding and investment vehicles.

Loss carry-forward is unlimited with no time cap. Losses from one year can be carried forward indefinitely to offset future taxable income.

EEA member since 1995 — access to the EU single market for goods, services, capital, and persons under the EEA Agreement. This provides market access without EU membership and the corresponding EU budget contributions.

The Anstalt (Establishment) is a legal structure found only in Liechtenstein. A single-owner vehicle with full legal personality and no publicly registered shareholders — used for holding, IP, and wealth planning without a share-based structure.

Formal recognition of Anglo-Saxon trusts in a civil law system. Liechtenstein is one of very few civil law countries globally to give full legal effect to trust structures — relevant for cross-border estate and tax planning involving multiple jurisdictions.

Swiss Franc (CHF) currency. The CHF has maintained stable purchasing power over decades relative to EUR, USD, and most other currencies. Low currency risk for CHF-denominated structures.

30+ double tax treaties in force, covering Germany, Austria, Switzerland, UK, UAE, Singapore, Hong Kong, Luxembourg, Georgia, and others — reducing cross-border withholding tax costs for qualifying structures.

OECD BEPS compliant and CRS participant since 2016. Liechtenstein is a FATF member with mandatory UBO registration. Structures formed here carry reputational credibility that pure offshore secrecy jurisdictions no longer offer.

Minimum paid-in capital of CHF 50,000 for an AG or CHF 30,000 for a GmbH, Anstalt, or Foundation. Capital must be physically deposited in a Liechtenstein bank account before registration can proceed — a cash commitment from day one.

1% formation tax on paid-in capital applies at incorporation. On a CHF 50,000 AG, that is CHF 500 in tax at formation, on top of notary fees, Trade Register fees, and professional service costs.

CHF 1,800/year minimum corporate income tax applies regardless of profit. A zero-revenue or loss-making holding company still owes CHF 1,800 in annual CIT — plan for this as a fixed recurring floor cost.

Corporate bank account opening requires an in-person meeting at the bank or a formal introduction from a Liechtenstein-licensed trustee. Remote corporate account opening is not standard at any of the major Liechtenstein banks; KYC and AML requirements are strictly enforced.

Non-EEA nationals face a strict annual residency quota. The number of new non-EEA residents permitted in Liechtenstein each year is fixed by law. Obtaining personal residency here — even with a corporate presence — is not guaranteed and can take years.

Economic substance requirements follow OECD guidelines. A holding company registered in Liechtenstein with no genuine management activity, resident directors, or operational presence faces increasing scrutiny and potential challenge to double tax treaty benefit eligibility.