Liechtenstein Holding Company: Structures with a Licensed Local Trustee

Not as a flat rule. Dividends from participations and gains on selling them are excluded from taxable income (SteG Art. 48(1)(e), (f)). That stops when the payer can deduct the dividend and the stake is at least 25%, or a foreign payer earns more than 50% passive income and is lightly taxed. You must prove it (Art. 48(7)).

That depends on your home country's law, and ABB gives no opinion on it. Liechtenstein taxes a company whose seat or place of effective management is in Liechtenstein (SteG Art. 44(1)). Your own foreign advisers must confirm the home position, and the licensed trustee works from their view. Nothing on this page promises a foreign outcome.

The Act tests the seat or the place of effective management (SteG Art. 44(1)); we found no published criteria beyond that wording. Most entities need a licensed trustee (or Art. 180a licence holder) on the board (PGR Art. 180a), and the mandate is a trustee activity. What that mandate does for substance is not asserted here.

Any of the three can carry the role: a holding is a role, not a form. The criteria differ: minimum capital CHF 50,000, CHF 10,000 or CHF 30,000; articles by public deed for an AG and a GmbH, written statutes for an Anstalt; full accounts for an AG and a GmbH. You choose with the licensed partner.

A PVS carries on no economic activity, its shares are not placed publicly, and neither it nor its owners may exert actual control over participations. It pays the minimum tax only; a holding that controls its subsidiaries is not a PVS. The taxpayer confirms the conditions on application and yearly; the Tax Administration decides and checks (SteG Art. 64).

In the Tax Act text read for this page we found no chapter on withholding tax on outbound dividends, which is not the same as a flat "none". Other states may levy source tax on persons resident in Liechtenstein; the Tax Administration publishes the maximum rates from treaties and the EEA agreement. Check that table for your country.

The Tax Administration overview, state 21 October 2026, lists 32 agreements; by our count 26 are in force and six are signed or initialled but not in force. It matters because exempt dividends leave no Liechtenstein tax to credit foreign source tax against. Country rates stay in the Tax Administration table.

Minimum income tax is CHF 1,800 per year, creditable against income tax, subject to the exception in SteG Art. 62(3): it is not levied on an entity run exclusively as a commercial business with a balance-sheet total averaging at most CHF 500,000 over three years. A holding is by default not a commercial business, so it normally pays it.

Usually two roles. Most entities need at least one board member who holds a Trustee Act licence or an Art. 180a supervision-act authorisation, treated as equal (PGR Art. 180a(1)-(3)). A Repräsentant, an EEA national permanently resident in Liechtenstein or a domestic legal person appointing one, represents the entity towards the authorities (Art. 239). The licensed trustee arranges both.

Only if your group qualifies. The Liechtenstein top-up tax covers units of groups whose ultimate parent reports annual revenue of at least EUR 750 million in at least two of the four preceding years (GloBE-Gesetz Art. 4(1)), at a minimum rate of 15% (Art. 5(3)). The Act is in force since 1 January 2024.

It can be, if its form fits: a holding is a role of the entity, not a form. Check two things on an old company: the old-reserves rule continues to apply to equity existing on 1 January 2011 (SteG Art. 158), and the beneficial-owner report. The ready-made companies page has the details.

An AG or a GmbH holding keeps full annual accounts even without a commercial business (PGR Art. 1045(2)), prepared within six months of the year end. An Anstalt without a commercially run business keeps records in proportion to its assets. The tax return documents are in German; a licensed trustee prepares the return under a written power of attorney.

Beneficial owners are reported within 30 days of the register entry and of learning of a change (VwbPG Art. 4). Since the cyberattack of 30 July 2026, deadlines that cannot be met are suspended (Office of Justice page, updated 21 October 2026). Access is limited, identification in person in Vaduz since 5 October 2026; no end date is published.

Not ABB. Forming a company for third parties, board mandates, tax advice and filings are trustee activities (TrHG Art. 2). ABB collects your documents, prepares the draft and coordinates; a licensed Liechtenstein trustee, named in the engagement letter, forms the company, provides the qualified board member and files. ABB holds no board seat and gives no tax opinion.

It exists from the register entry, not from signing (PGR Art. 538(2)). The capital rule reads two ways: PGR Art. 122(2) and the Office of Justice leaflet require minimum capital to be paid in or contributed in full; PGR Art. 537(2) no. 2 has the deed declare it paid in at least by half. The licensed partner confirms the route.