Liechtenstein Holding Company: Form, Tax and Process
A holding is a role that an AG, a GmbH or an Anstalt plays. We prepare and coordinate the file; a licensed Liechtenstein trustee, named in your engagement letter, forms the company, files and acts.
- A holding is a role, not a legal form
- Exemption with limits (SteG Art. 48)
- Reserved acts by a licensed trustee
What's included
This page is for owners, families and advisers who want to hold participations through Liechtenstein, using one of the forms of our company formation service: our company formation service. In law a holding is a role of the entity, not a legal form (PGR Art. 107(3)); forming a company for third parties is a trustee activity (TrHG Art. 2), so we prepare and the licensed trustee forms and files.
Structure memo
We set out what the holding will own, where and for whom. The tax conclusions in it are the licensed trustee's work.
Form comparison
AG, GmbH and Anstalt side by side on the statutory criteria: capital, control, formation instrument, accounts and register fee.
Formation documents
We collect and draft the papers; the licensed trustee forms the company and files it with the Office of Justice.
Board member and Repräsentant
We arrange the qualified board member and the representative towards the authorities that the entity needs.
Participations and tax
We coordinate the transfer of participations. The trustee handles tax representation, an optional ruling request and PVS status where it fits.
Ongoing duties
We keep the beneficial-owner report, the annual accounts and the tax return documents on schedule with the trustee.
AG, GmbH or Anstalt as the holding
Each form can carry a holding. The criteria below come from the statute; the choice is yours.
Minimum capital by form
Capital
AG CHF 50,000, GmbH CHF 10,000, Anstalt CHF 30,000 (PGR Art. 122(1)), paid in full under Art. 122(2). For an Anstalt, Art. 537(2) no. 2 also asks for a declaration of at least half; table 1 states both.
Control and transfer
An AG or GmbH is held through shares; see Liechtenstein GmbH formation. In an Anstalt the founder's rights holders form the supreme body (Art. 543(1)); those rights can be assigned and inherited, not pledged (Art. 541).
Formation instrument
An AG and a GmbH are formed by public deed. An Anstalt needs written statutes (Art. 536(1)), and the filing carries a certified copy signed by all founders; see our Anstalt formation service.
Accounts and register fee
An AG or GmbH keeps full accounts (Art. 1045(2)); an Anstalt without a commercial business keeps proportionate records (Art. 1045(3)). The basic register fee is CHF 700 for each form.
How setting up a holding works
No official processing time is published for the register entry, a PVS decision, a ruling or a bank account.
Seven steps to a Liechtenstein holding
Client
LFF Heritage Trusts
Licensed trustee and notary
Purpose memo
You tell us the participations, the subsidiaries' countries, the owners and where the board will sit. We prepare the memo. Who: client, LFT.
Form comparison
We set the AG, GmbH and Anstalt criteria against your plan. You decide with the licensed partner. Who: client, licensed partner.
Formation and register entry
Public deed or written statutes. Entries are made in German; supporting documents may be filed in another language (HRV Art. 4). Who: licensed trustee, notary.
Board member and Repräsentant
A licensed trustee or Art. 180a licence holder joins the board, with exceptions in Art. 180a(3); a Repräsentant is appointed (Art. 239). Where decisions are taken is your call (SteG Art. 44(1)). Who: licensed trustee, client.
Participations
They are acquired or contributed with your foreign counsel, and transfer prices are determined and documented under the rules the Government sets by ordinance (SteG Art. 49(3)). Who: client, LFT coordinates.
Tax
The trustee represents the company under a written power of attorney (SteG Art. 90), frames any ruling request and checks PVS conditions; see tax planning for a family's structure. Who: licensed trustee.
Ongoing
The beneficial-owner report is due within 30 days of entry and of knowing a change (VwbPG Art. 4). Accounts follow within six months (PGR Art. 1048(2)); return documents are in German (SteG Art. 94(3)). Who: licensed trustee, client.
Beneficial-owner register status: access has been limited since the cyberattack of 30 July 2026; it resumed in limited form from 5 October 2026, with identification in person in Vaduz, and deadlines that cannot be met remain suspended, with no end date published (Office of Justice register page).
Not sure which entity should carry your holding?
Send us your participations and owners. We prepare the AG, GmbH and Anstalt comparison for your case.
Documents you will need
Bring these to the first review with the licensed trustee.
- The intended participations, the subsidiaries' countries and the owners
- Where the board will take its decisions
- Photo ID of the owners and beneficial owners, for the trustee's due diligence
- Capital at the form's minimum: AG CHF 50,000, GmbH CHF 10,000, Anstalt CHF 30,000, paid as that form requires
- Signatures on the formation documents; for an Anstalt, the statutes signed by all founders
- The papers for acquiring or contributing the participations
- Your own foreign advisers' view of home-country tax
- Register documents in German, or ready for a certified translation on request
Requirements, tax and official fees
Statute and official-schedule facts only. No fee of LFT or of the partner appears here; pricing on request.
What a Liechtenstein holding requires and how it is taxed
| Item | Rule | Who acts | Source |
|---|---|---|---|
| Capital and payment | AG CHF 50,000, GmbH CHF 10,000, Anstalt CHF 30,000, paid in or contributed in full; for an Anstalt Art. 537(2) no. 2 also asks for a declaration that at least half is paid in, and the page does not reconcile the two | the founders | PGR Art. 122(1), (2), 537(2) no. 2; Office of Justice Merkblatt zur Anstalt 06/2025 |
| Formation instrument | AG and GmbH by public deed; Anstalt by written statutes, the filing carrying a certified copy signed by all founders | licensed trustee, notary | PGR Art. 536(1); HRV Art. 84(1)(b) |
| Accounts | full accounts for an AG or GmbH even without a commercial business; an Anstalt without one keeps records proportionate to its assets, full accounts if it runs one; within six months after year end | the company, licensed trustee | PGR Art. 1045(1)-(3), 1048(2) |
| Corporate income tax | 12.5 % of taxable net income, for a company with its seat or place of effective management in Liechtenstein | Tax Administration | SteG Art. 44(1), 61 |
| Participation exemption | dividends and gains on participations excluded from taxable net income; not for deductible dividends on a stake of 25 % or more, nor for a foreign payer more than 50 % passive (interest, IP royalties, finance leasing) and lightly taxed; burden of proof on the taxpayer | taxpayer, Tax Administration | SteG Art. 48(1)(e), (f), (3), (4)(a), (7) |
| Minimum tax | CHF 1,800 a year, creditable against the income tax, subject to the exception in SteG Art. 62(3): an exclusively commercial purpose and a balance-sheet total averaging at most CHF 500,000 over three years | Tax Administration | SteG Art. 62(1)-(3) |
| Private asset structure (PVS) | no economic activity; holds participations only without actual control; pays only the minimum tax; conditions confirmed on application and yearly | taxpayer, Tax Administration decides | SteG Art. 64(1)(a), (2), (4), (8) |
| Board member and Repräsentant | most entities need a licensed trustee or Art. 180a licence holder on the board, exceptions in Art. 180a(3); a Repräsentant, an EEA national permanently resident in Liechtenstein, represents the entity towards the authorities | licensed trustee | PGR Art. 180a, 239(1), (4) |
| Language | register entries in German; supporting documents may be in another language, a certified translation on request; tax return documents in German | the filing party | HRV Art. 4(1), (2); SteG Art. 94(3) |
| Beneficial owners | report within 30 days of entry and of knowing a change; access limited since 30 July 2026, limited resumption from 5 October 2026, deadlines that cannot be met suspended | licensed trustee | VwbPG Art. 4(4)(a), (5); Office of Justice register page, 21 October 2026 |
| Treaties | 32 agreements listed, 26 in force, state 21 October 2026 (our count from the table) | Tax Administration | Tax Administration treaty overview |
| Global minimum tax | groups whose ultimate parent has revenue of at least EUR 750 million in at least two of the four preceding years; minimum rate 15 %; in force 1 January 2024 | the group, Tax Administration | GloBE Act Art. 4(1), 5(3), 31(1) |
Source: PGR; SteG, version of 1 July 2026; VwbPG; treaty overview; source-tax table. The register ordinance (HRV), the GloBE Act and the Merkblatt zur Anstalt are cited in words.
Official register fees for a new holding company
| Item | Official amount | Version | Source |
|---|---|---|---|
| Register entry, AG | CHF 700 basic fee | 1 August 2024 | GbHr-GebV Anhang 2 B.1(c) |
| Register entry, Anstalt | CHF 700 basic fee | 1 August 2024 | GbHr-GebV Anhang 2 B.1(i) |
| Register entry, GmbH | CHF 700 basic fee | 1 August 2024 | GbHr-GebV Anhang 2 B.1(e) |
| Capital surcharge | 0.2 per mille of the capital above CHF 200,000; the fee with the surcharge at most CHF 10,000 | 1 August 2024 | GbHr-GebV Anhang 2 B.2 |
| Signatories and functions | CHF 30 per signatory, CHF 20 per function entered | 1 August 2024 | GbHr-GebV Anhang 2 B.4 |
Source: GbHr-GebV, version of 1 August 2024. No total is quoted. The notarial fee for an AG, certification, trustee and partner fees are not stated; they are quoted on request.
Problems we solve
"Tax-free holding" claims
Dividends and participation gains are exempt, with limits and the burden of proof on you (SteG Art. 48). The rate is 12.5 % (Art. 61); the general profit tax is in the corporate tax guide: the corporate tax guide.
Substance
The statute taxes by the seat or place of effective management (SteG Art. 44(1)). We found no published substance criteria beyond that wording, and we state no outcome in your home country.
A licensed trustee on the board
Most entities need a licensed trustee or Art. 180a licence holder on the board, with the exceptions in Art. 180a(3). The mandate is a trustee activity; we do not say what it does for substance.
Holding, PVS or foundation
A PVS is passive and exerts no control (SteG Art. 64), so a control holding is not a PVS. A Liechtenstein family foundation is a different vehicle, set up by a written declaration with certified signatures (PGR Art. 552 § 14(1)); trusts and charitable foundations are separate again.
Treaties and source tax
Of 32 agreements listed, 26 are in force (state 21 October 2026). We found no chapter on outbound dividend withholding in the SteG text we read. Exempt dividends leave nothing to credit; the Tax Administration table lists source-tax rates.
An Anstalt as the holding
An Anstalt exists in law only on its register entry (PGR Art. 538(2)), not on signing. Its capital rules sit side by side: paid in full (Art. 122(2), leaflet 06/2025) or declared at least half paid (Art. 537(2) no. 2).
The bank account
Account opening is the bank's decision and a separate step, and nothing is promised here. The guide on what a Vaduz bank asks before it opens an account for a foundation covers the questions.
Buying a ready-made company
A buyer inherits the company's history. The old coupon-tax rules continue for old reserves, the equity existing on 1 January 2011 (SteG Art. 158(1), (2), 160(1)).
Want the tax limits and the board checked for your case?
We set your participations against the exemption limits and the board rules; the licensed trustee checks the reserved parts.
Why work with us
Dominik Heeb keeps your holding file together in Vaduz, from the structure memo to the yearly beneficial-owner report. We prepare, check and coordinate; the licensed Liechtenstein trustee named in your engagement letter forms, files and acts. Every figure on this page carries its article and version.
Frequently asked questions
Is a Liechtenstein holding tax-free on dividends and share sales, and what are the exceptions?
Not without limits. Dividends and gains on participations are excluded from taxable net income (SteG Art. 48(1)(e) and (f)). The exemption falls away for deductible dividends on a stake of 25 % or more, and for a foreign payer that is lastingly more than 50 % passive and lightly taxed. The taxpayer must prove the conditions (Art. 48(3) to (7)).
Will my home tax authority still tax the holding or me?
The SteG taxes a company by its seat or place of effective management (Art. 44(1)). Whether your home country also taxes the holding or you depends on your own position, and this page states no outcome. Take the home-country view from your own advisers before the structure is formed.
How much substance does the holding need, and can the board member be a nominee?
The statute names the seat or the place of effective management (SteG Art. 44(1)), and we found no published substance criteria beyond that wording. Most entities need a licensed trustee or Art. 180a licence holder on the board. The mandate is a trustee activity, and this page does not say what it does for substance.
Which form can carry a holding: AG, GmbH or Anstalt?
The page recommends none. The criteria are minimum capital (AG CHF 50,000, GmbH CHF 10,000, Anstalt CHF 30,000), the supreme body and transfer rules of an Anstalt, the formation instrument, the accounts duty and the register fee. You decide with the licensed partner, who is named in your engagement letter.
What is the difference between a holding company and a private asset structure (PVS)?
A PVS carries on no economic activity and may hold participations only if no actual control is exerted over their management (SteG Art. 64). It pays only the minimum tax. A control holding is therefore not a PVS. The taxpayer confirms the conditions on application and yearly, and the Tax Administration decides the status.
Is there a withholding tax on dividends paid out of Liechtenstein?
We found no chapter on withholding tax on outbound dividends in the SteG text we read, so we do not say there is none. The Tax Administration publishes the maximum source-tax rates other states may levy on persons resident in Liechtenstein. The SteG source deductions shown concern employment income and fees to board members resident abroad.
How many double-tax treaties does Liechtenstein have, and does that matter for a holding?
The Tax Administration overview, state 21 October 2026, lists 32 agreements, of which 26 are in force and 6 are signed or initialled but not yet in force; the count is our own from the archived table. It matters little for exempt dividends, because they leave no Liechtenstein tax to credit foreign source tax against.
What minimum tax does a holding with no income pay each year?
CHF 1,800 a year, fully creditable against the income tax, always subject to the exception in SteG Art. 62(3). A holding is by default not a commercially run business (PGR Art. 107(3)), so it normally pays it. The exception needs a purpose exclusively of a commercially run business and a balance-sheet total averaging at most CHF 500,000.
Do I need a local director and a representative in Vaduz?
Most entities need a licensed trustee or Art. 180a licence holder as a board member authorised to manage and represent the company (PGR Art. 180a); paragraph 3 sets exceptions. A Repräsentant, an EEA national permanently resident in Liechtenstein, represents the entity towards the authorities (Art. 239) and needs no licence; the duty can lapse with Government consent.
Does the global minimum tax (Pillar Two) apply to my holding?
Only for Liechtenstein units of groups whose ultimate parent reports annual revenue of at least EUR 750 million in at least two of the four preceding years. Those units fall under the Liechtenstein top-up tax at a minimum rate of 15 % (GloBE Act Art. 4(1) and Art. 5(3)); the Act is in force since 1 January 2024.
Can I buy a ready-made company and use it as a holding?
Buyers are routed to our ready-made company page, which explains what a buyer inherits. One fact applies here: the old coupon-tax rules continue to apply to old reserves, meaning the equity existing on 1 January 2011 (SteG Art. 158(1) and (2), Art. 160(1)). We do not assess here whether a given company suits a holding.
What accounts and filings does a holding have to keep each year?
An AG or GmbH holding always keeps full annual accounts, even without a commercial business (PGR Art. 1045(2)). An Anstalt without a commercially run business keeps records proportionate to its assets, and full accounts if it runs one. Accounts are prepared within six months after year end, and tax return documents are written in German.
What must be reported to the beneficial owners register, and what is its state after the 2026 cyberattack?
The report is due within 30 days of register entry (VwbPG Art. 4) and within 30 days of knowing a change. After the cyberattack of 30 July 2026, access resumed in limited form from 5 October 2026, with identification in person in Vaduz. Deadlines that cannot be met stay suspended, with no end date published.
Who forms the company and sits on the board: LFT or a licensed trustee?
A licensed Liechtenstein trustee, named in your engagement letter, forms the company, files it and provides the board member. LFT prepares, collects the documents and coordinates. Tax conclusions are the trustee's work, and bookkeeping is done by a trustee or a trade-licence bookkeeper.
When does an Anstalt used as a holding exist in law, and how is its capital paid in?
An Anstalt arises and acquires legal personality only with the register entry (PGR Art. 538(2)), not on signing. On capital, two rules stand side by side: Art. 122(2) and the Office of Justice leaflet of 06/2025 say paid in or contributed in full, while Art. 537(2) no. 2 asks for a declaration of at least half.
Ready to plan your holding?
Call the Wealth Management department on +423 210 0004, Monday to Friday 09:00-17:30 (CET/CEST), or write to info@foundation-liechtenstein.com. LFF Heritage Trusts, Schlossplatz 5, 9490 Vaduz.