Tax Advisor in Liechtenstein: Tax Advice and Rulings for Foundations and Companies
A licensed Liechtenstein trustee, named in your engagement letter, gives the tax advice. LFT collects the facts, prepares the file and coordinates, from scoping to a binding ruling.
- Corporate income tax 12.5%
- Minimum tax CHF 1,800 a year
- Binding rulings on application
- 30 days to appeal a PVS decision
Tax advisory for Liechtenstein foundations, trusts and companies
This page is for owners of a foundation, trust or company and their advisers. Tax advice for third parties is a trustee activity under the TrHG, so a licensed trustee advises and files, as when setting up a foundation with a licensed Liechtenstein trustee. LFT prepares and coordinates.
LFT gives no tax advice itself, gives no legal advice and promises no tax result. Professional legal advice and party representation are reserved to lawyers (RAG Art. 8(1)); the statutory powers of trustees, tax advice among them, stay untouched (Art. 8(3)). For rates and how each tax works, read the tax system of Liechtenstein.
What's included
VAT has its own rules, set out in how VAT applies to a Liechtenstein company and its invoices.
Scoping
We collect the facts of the structure and list the tax questions. The licensed trustee advises on them.
Binding ruling application
We collect the facts and prepare the document list for an application on a fact pattern not yet realised. The licensed trustee or lawyer drafts the legal questions and the tax-law assessment and submits it.
Private-asset-structure application
Where the entity may qualify, we assemble the facts and documents for the PVS application. The licensed trustee prepares the application and the confirmation under a written power of attorney; the taxpayer confirms the conditions; the Tax Administration decides.
Representation and the annual return
The trustee represents you under a written power of attorney; the annual figures come through our accounting service.
Pillar Two coordination
Only for groups at or above the Pillar Two threshold. We coordinate the return and the notifications with the licensed partner.
Who this is for
Founders and beneficiaries
You ask how a structure sits beside your own taxes. The income tax guide and Liechtenstein wealth tax explain the rules; the trustee advises.
Holding owners
You hold a Liechtenstein holding beneath a foundation and ask whether its dividends fall under the participation exemption.
Regulated businesses
You need the FMA approval a regulated business needs in Liechtenstein first, and the tax position beside it.
Shelf-company buyers
You buy a shelf company Liechtenstein and want its tax position settled before you use it.
How the process works
Official timing appears only where a statute gives one. We found no official processing time for a ruling, and this page prints no fee amount: the fee follows the government's fee ordinance (SteV Art. 38a(5)).
Seven steps of tax work in Liechtenstein
Scoping and engagement
Who acts: Client, LFT, licensed trustee
Written power of attorney; domestic representative if the seat is abroad
Who acts: Client, trustee
Binding ruling application
No processing time stated
Who acts: Trustee, under the Tax Administration rules
PVS status, confirmed every year; appeal within 30 days
Who acts: Tax Administration decides; licensed trustee
Annual return in German, signed personally and filed electronically; six-month extension on request
Who acts: Taxpayer signs, trustee files
Pillar Two return: 15 months after year end, 18 the first time
Who acts: Licensed partner, LFT coordinates
Assessment, objection and appeal
Who acts: Tax Administration; licensed trustee or a lawyer
Scoping and engagement
We collect the facts and the questions; the engagement letter names the licensed trustee who advises. Who: client, LFT, licensed trustee.
Power of attorney
You sign a written power of attorney for the trustee; a taxpayer seated abroad may be asked to name a domestic representative. Who: client, licensed trustee.
Binding ruling
The trustee submits the written application before the structure is set up; the Tax Administration rules, with no stated processing time. Who: licensed trustee, Tax Administration.
PVS status
The Tax Administration decides on the application; the conditions are confirmed every year, and a decision can be appealed within 30 days. Who: Tax Administration, licensed trustee.
Annual return
Signed personally, in German, and filed electronically from tax year 2024 (newsletter 11/2024); the deadline is set each year. Who: taxpayer, licensed trustee.
Pillar Two return
For an in-scope group, due 15 months after the year end, 18 months the first time. Who: licensed partner, LFT coordinates.
Assessment and appeal
The Tax Administration assesses; an objection or appeal follows the statute, and the licensed trustee acts within its statutory powers or a lawyer handles it where needed. Who: Tax Administration, licensed trustee, lawyer.
Not sure which tax question to settle first?
Send us the structure and your questions. We prepare the file for the licensed trustee, who gives the consultation.
Documents you will need
- The facts of the structure: entity, founder, owners, beneficiaries, residence, activity
- A signed written power of attorney
- A named domestic representative, if the seat is abroad and asked
- For a ruling: the full fact pattern and your own tax view
- The figures and supporting documents for the return
- Attachments in English, where the ordinance lists them
- The signed confirmation that the return is complete and true
- The passcode from the information letter
- For PVS status: the yearly confirmation of the conditions
Liechtenstein tax requirements at a glance
These figures are the statute's, not an LFT offer; the full method is in how corporate tax is calculated for a Liechtenstein company.
A binding ruling and PVS status
What it covers
Binding ruling: A fact pattern not yet realisedPVS status: The entity's tax statusHow it starts
Binding ruling: On applicationPVS status: The Tax Administration decides on the applicationHow long it holds
Binding ruling: Binds while the later facts match; ends when the law changes or a time limit runs outPVS status: Conditions confirmed every yearTax effect
Binding ruling: Binds while the later facts matchPVS status: Pays only the minimum tax and is not assessed
A ruling settles a question; PVS status sets how the entity is taxed.
What the statutes set for the tax of a Liechtenstein entity
| Requirement | Rule | Source |
|---|---|---|
| Corporate income tax rate | 12.5% of taxable net income | SteG Art. 61; Tax Administration page |
| Minimum corporate income tax | CHF 1,800 a year; not levied where a trade-only taxpayer's balance-sheet total averages up to CHF 500,000 over three years | SteG Art. 62(2), (3) |
| Reach of the tax | Seat or place of effective management in Liechtenstein: taxed without limit on the entire income | SteG Art. 44(1), Art. 2(1)(d) |
| Binding ruling: application | On application, for a precisely defined fact pattern not yet realised; written, names the applicant, full facts, concrete questions, own tax-law assessment; an official fee by ordinance | SteG Art. 93a(1), (3); SteV Art. 38a(1) |
| Binding ruling: effect and end | Binds if later facts do not differ or differ only insignificantly; ends when the provisions change or a time limit expires; revocable for the future if incorrect | SteV Art. 38a(2), (3), (4) |
| Return: signature and language | Signed personally, with a signed confirmation of completeness; German; listed attachments may be in English | SteG Art. 94(2), (3); SteV Art. 41(2)(f), (3) |
| Return: filing | Electronic for legal persons from tax year 2024; deadline set yearly | SteV Art. 42a; newsletter 11/2024; SteG Art. 95 |
| Return: extension | Six months on a reasoned written request within 30 days after the general due date; provisional invoice paid | SteV Art. 42(1), (2) |
| Pillar Two | Groups with consolidated revenue of at least EUR 750 million; return 15 months after year end, 18 the first time | GloBE-Gesetz Art. 4(1); Tax Administration page |
| PVS decision | The Tax Administration decides, appeal within 30 days; a PVS pays only the minimum tax and is not assessed | SteG Art. 64(5), (8) |
| Participation exemption | Dividends from participations excluded; limits for holdings of 25% or more and for foreign payers; the taxpayer proves the limits do not apply | SteG Art. 48(1)(e), (3), (7) |
| Procedural and evasion fines | Up to CHF 1,000, serious or repeat up to CHF 10,000; evasion normally one times the evaded tax; knowingly contributing up to CHF 10,000, serious or repeat up to CHF 50,000 | SteG Art. 135, 137, 139(2) |
Source: SteG, SteV, Tax Administration page on corporate income tax, GloBE-Gesetz.
Private-asset structure (PVS): the conditions
A PVS is taxed only at the minimum tax; how a foundation qualifies is in Liechtenstein foundation tax.
- No economic activity, in particular where the entity only acquires, holds, manages and sells financial instruments, holdings in legal persons, cash and bank balances
- Shares not placed publicly or traded on an exchange
- Reserved to private investors, restrictions written into the statutes
- No solicitation of investors, no remuneration or cost reimbursement
- No actual control of the management of held companies
- Conditions and compliance with the accounting duty (PGR Art. 1045 ff.) confirmed to the Tax Administration, every year
Problems we solve
"Who may advise me?"
Tax advice for third parties is a trustee activity, and the trade act excludes tax advisers. LFT collects and coordinates; the licensed trustee advises.
"A low rate means no tax"
A Liechtenstein rate and minimum tax do not decide what another state taxes. No structure is tax-free by itself; see the tax haven question guide.
"Old figures in circulation"
The IP box ended with tax year 2020, and the minimum tax is CHF 1,800. A brand is a trademark matter: see protecting a family brand in Liechtenstein and abroad.
"My dividends are exempt"
The participation exemption has limits: holdings of 25% or more where the payer deducts the payout, and foreign payers with mostly passive, lightly taxed income. The taxpayer carries the burden of proof.
"A ruling lasts for ever"
A ruling ends when the law it rests on changes or a time limit runs out, and can be revoked for the future if incorrect.
Want a ruling or a status settled before the structure is set up?
Tell us the planned structure. We collect the facts and documents for the ruling or PVS file; the licensed trustee prepares and submits it.
Why work with us
Corinne Sele, our tax, accounting and licensing lead, prepares the file. Professional legal advice is reserved to lawyers under the RAG, which leaves the statutory powers of trustees untouched.
Frequently asked questions
Who may give tax advice in Liechtenstein, and who gives it through LFF Heritage Trusts?
Tax advice for third parties is a trustee activity (TrHG Art. 2(d)); lawyers also carry it out, and the trade act excludes tax advisers (GewG Art. 3(f)). Through LFT, a licensed Liechtenstein trustee, named in your engagement letter, gives the advice. LFT collects the facts, prepares the file and coordinates the work.
Does LFT itself advise on tax or represent me before the Tax Administration?
No. LFT collects the facts, prepares the document list and coordinates. The licensed trustee acts for you under a written power of attorney (SteG Art. 90). Professional legal advice and party representation are reserved to lawyers (RAG Art. 8(1)), but the statutory powers of trustees stay untouched (Art. 8(3)). LFT submits nothing to the authority itself.
What does a tax advisor in Liechtenstein cost?
Pricing is on request: the cost follows the structure, the questions and the filings involved, so no figure is given here. A binding ruling application is charged an official fee under the government's ordinance on administrative costs and fees, and this page prints no amount. Send your questions through the enquiry form.
Can tax advice guarantee that my company or structure pays no tax?
No. The corporate income tax rate is 12.5% of taxable net income, with a minimum of CHF 1,800 a year (SteG Art. 61, Art. 62(2)). Relief and exemptions apply only on their conditions, and this page cannot tell you which regime fits your case. The licensed trustee advises on your facts; no tax result is promised.
Can a binding ruling or private-asset-structure status be guaranteed?
No. The Tax Administration decides on each application. A binding ruling covers only the facts described and binds the assessment while later facts do not differ, or differ only insignificantly (SteV Art. 38a(2)). Private-asset-structure status is granted on application to a legal person that meets the statutory conditions (SteV Art. 37(1)). No outcome is promised.
What is the corporate income tax rate and the minimum tax in 2026?
Corporate income tax is 12.5% of taxable net income (SteG Art. 61, 2026 consolidated text), and the minimum corporate income tax is CHF 1,800 a year (Art. 62(2)). The Tax Administration's own page gives the same rate and minimum. If you find a different minimum elsewhere, treat it as out of date.
When is the minimum tax not charged?
The minimum tax is not charged to a taxpayer whose sole purpose is a commercially run trade and whose balance-sheet total averaged at most CHF 500,000 over the last three financial years (SteG Art. 62(3)). A private-asset structure pays only the minimum tax and is not assessed (Art. 64(8)). Both rules apply only on their conditions.
What is a private-asset structure (PVS) and what are its conditions?
A private-asset structure is a legal person taxed only at the minimum tax if it meets the statutory conditions: no economic activity, shares reserved to private investors with the restrictions in its statutes, no solicitation of investors, no actual control of held companies. The taxpayer confirms the conditions on application and every year (SteG Art. 64).
How long does a binding tax ruling take and what does it cost?
No official processing time was found, so none is promised. A fee is charged for assessing the application and follows the government's ordinance on administrative costs and fees (SteV Art. 38a(5)); this page prints no amount because the ordinance, not LFT, sets it. Pricing of our own work is on request.
What must a ruling application contain?
The application is written and names the applicant. It describes the facts in full, sets out concrete legal questions and gives the applicant's own tax-law assessment (SteV Art. 38a(1)). It concerns a precisely defined fact pattern not yet realised (SteG Art. 93a(1)), so the facts are collected before the structure is set up.
How long does a ruling stay binding?
A ruling binds the assessment while the later facts do not differ from those assumed, or differ only insignificantly (SteV Art. 38a(2)). It ends when the provisions it rests on are repealed or amended, or when a time limit expires. The Tax Administration can also revoke or change it for the future if it proves incorrect.
Who signs the annual tax return, in which language, and is it filed online?
The taxpayer signs the return personally, and the file carries a signed confirmation that it is complete and true. The documents are in German; the attachments listed in SteV Art. 41(2) may also be in English. Returns of legal persons are filed electronically from tax year 2024, and the passcode arrives with the information letter.
Can I get an extension for the tax return?
An extension can be requested. The Tax Administration may extend the deadline by six months on a reasoned written request made no later than 30 days after the general due date, once the provisional invoice is paid (SteV Art. 42). A further extension is possible in specially justified cases. The authority decides and sets the deadline itself each year.
Does Pillar Two apply to my group?
Only if the group has consolidated annual revenue of at least EUR 750 million in at least two of the four preceding years (GloBE-Gesetz Art. 4(1)). Below that line the Pillar Two rules do not apply. The return is due 15 months after the year end, 18 months the first time. Reporting entities use the LIDES portal.
Ready to set out your tax questions?
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. Pricing on request.