Tax Advisor Liechtenstein: Advice Through a Licensed Trustee
We collect the facts and prepare the file; a licensed Liechtenstein trustee advises and acts before the Tax Administration. Every 2026 figure is shown with its source.
- Corporate income tax 12.5%
- Minimum tax CHF 1,800
- Binding rulings on application
- Advice by a licensed trustee
Tax advice in Liechtenstein: who does what
A tax advisor in Liechtenstein acting for third parties needs a trustee permit or a lawyer's admission: tax advice is a trustee activity under the Trustee Act (TrHG), Art. 2(d). Tax advisers sit outside the trade act, so no trade licence replaces that permit. The Tax Administration assesses companies, decides private-asset structure status and answers ruling applications.
ABB collects the facts, prepares the file and coordinates the dates. The licensed trustee, named in the engagement letter, advises and acts before the authority; legal advice stays with a lawyer. Company formation itself is on the detailed market entry page.
What's included
Scoping the questions
We map your structure, income and planned transactions, so the licensed trustee sees which rules apply and which questions need a written answer.
Binding ruling application
We assemble the facts in full, the concrete legal questions and your own tax-law assessment, which a tax ruling in Liechtenstein requires; the trustee files it.
Private-asset structure application
We collect the evidence for the private-asset structure (PVS) conditions. The taxpayer confirms them on application and yearly; the licensed trustee prepares the application and confirmation under a written power of attorney.
Representation under a power of attorney
You sign a written power of attorney, and the licensed trustee acts before the Tax Administration. A lawyer takes over where party representation is reserved.
Pillar Two coordination
For groups with consolidated revenue of EUR 750 million or more, we coordinate the minimum-tax return and GIR notifications with the trustee or your group tax team.
VAT is a separate file: see our VAT registration service and the VAT guide. Legal advice and party representation are reserved to lawyers under the Lawyers Act (RAG), Art. 8.
Who it is for
Founders moving a business
Founders who need to know what a foreign founder pays in tax after moving a business to Liechtenstein before they commit.
Holders of participations
Groups using a holding entity for participations and group financing that need the participation exemption and its limits checked.
Families with a private-asset structure
Families founding a family foundation with a licensed trustee who want PVS status examined before the first year.
Buyers of an existing company
Buyers choosing from the current list of companies available for purchase who need the tax position reviewed before signing.
Other files we coordinate: filing a national trademark with a local representative, the application file for a Liechtenstein financial licence, and, for residents, how wealth tax is assessed on a Liechtenstein resident's assets.
How the process works
The steps are practical. No processing time for a ruling is published, the filing deadline is set each year, and the cost is quoted on request.
Scoping and engagement
We collect the structure, the figures and your questions. The licensed trustee confirms the scope, and the engagement letter names the trustee.
Power of attorney
You sign a written power of attorney for the trustee. A taxpayer with its seat abroad may be asked to name a domestic representative.
Ruling application
We draft the fact pattern, the questions and your own assessment. The trustee files it, and the Tax Administration decides with no published timetable.
Private-asset structure status
The taxpayer confirms the conditions on application and each year; the trustee prepares the application and confirmation from the evidence we assemble. The Tax Administration decides, and the taxpayer can appeal within 30 days.
Annual tax return
The return is in German, signed personally and filed with the signed confirmation. Legal persons file electronically from tax year 2024.
Pillar Two return
Only at EUR 750 million or more: the trustee or group tax team files the return and GIR notifications; we coordinate the documents.
Assessment and objection
The Tax Administration assesses. If the assessment is disputed, the trustee or a lawyer handles the objection and any appeal.
Seven steps of tax advice and filings
Scoping and engagement
Who acts: Client, ABB, licensed trustee
Written power of attorney
Who acts: Client; domestic representative if the seat is abroad and the authority asks
Ruling application
No published time
Who acts: ABB drafts, licensed trustee files, Tax Administration decides
PVS status
Appeal within 30 days
Who acts: Taxpayer confirms, licensed trustee prepares, Tax Administration decides
Annual return in German, signed, electronic from tax year 2024
Who acts: Client signs, licensed trustee files
Pillar Two return and GIR, only at EUR 750 million or more
Who acts: Licensed trustee or group tax team, ABB coordinates
Assessment, objection, appeal
No published time
Who acts: Tax Administration; licensed trustee or lawyer
Sources: SteG, SteV, TrHG.
Ready to scope your tax questions?
Tell us your structure and the questions you need answered. Pricing on request.
What we need from you
- The facts of your structure: entities, holders, seat, management
- For a ruling, the full fact pattern and your questions
- A signed written power of attorney for the trustee
- A domestic representative, if the authority asks for one
- The return in German; attachments may be in English
- The signed confirmation that the return is complete and true
- The passcode from the information letter, kept by you
- For a PVS, your yearly confirmation of the conditions
Liechtenstein tax rules for entities: figures, rulings and filing
The figures below come from the 2026 consolidated texts. For the rate in more depth, see the Liechtenstein corporate tax rate guide.
Rates and base
Corporate income tax: rates and base (Tax Act, SteG, 2026 consolidated text; Tax Administration corporate income tax page).
| item | rule | source |
|---|---|---|
| Rate | 12.5% of taxable net income | SteG Art. 61 |
| Minimum tax | CHF 1,800 a year | SteG Art. 62(2) |
| Minimum-tax relief | 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 | SteG Art. 62(3) |
| Unlimited liability | seat or place of effective management in Liechtenstein | SteG Art. 44(1), Art. 2(1)(d), (e) |
| Participation exemption | dividends from participations excluded from taxable net income; limits for holdings of 25% or more where the payer deducts the distribution, and for foreign payers with more than 50% passive income and light taxation | SteG Art. 48(1)(e), 48(3), 48(7) |
| Notional interest deduction | cannot create or increase a loss; standard return 4% | SteG Art. 54(1), Art. 5(1) |
| Loss carry-forward | at most 70% of taxable net income | SteG Art. 57(1) |
| Directors' fees to non-residents | 12% withholding at source | SteG Art. 63a(3) |
| IP box | applied only up to tax year 2020 | SteG, transitional clause |
Sources: Tax Act (SteG); Tax Administration page on corporate income tax.
Rulings and status
From application to decision: a ruling and PVS status
Application
Ruling: Written application with the facts, the concrete questions and the applicant's own assessment (SteV Art. 38a(1))PVS status: Application, with the taxpayer's confirmation of the conditions (SteG Art. 64(4))Decision
Ruling: Tax Administration decides (SteG Art. 93a(1))PVS status: Tax Administration decides; appeal within 30 days (Art. 64(5))Validity
Ruling: Binds while the facts hold (SteV Art. 38a(2)); ends when the provisions change or a set time limit expires (Art. 38a(3))PVS status: Taxpayer confirms the conditions every year (Art. 64(4)); minimum tax only, no assessment (Art. 64(8))
Sources: SteG Art. 64, 93a; SteV Art. 38a.
Binding rulings and private-asset structure status (SteG and Tax Ordinance, SteV, 2026 consolidated texts).
| instrument | what it covers | how long it holds | source |
|---|---|---|---|
| Ruling | a precisely defined fact pattern not yet realised | while the later facts do not differ, or differ only insignificantly | SteG Art. 93a(1); SteV Art. 38a(2) |
| Binding commitment | a fact pattern already audited for the past | while the later facts do not differ, or differ only insignificantly | SteG Art. 93a(2); SteV Art. 38a(2) |
| Application | written, names the applicant, full facts, concrete questions, own assessment | not applicable | SteV Art. 38a(1) |
| End of binding effect | the underlying provisions are repealed or amended, or a set time limit expires | not applicable | SteV Art. 38a(3) |
| Revocation | for the future, if the ruling proves incorrect | not applicable | SteV Art. 38a(4) |
| PVS status | decided by the Tax Administration; appeal within 30 days | conditions confirmed by the taxpayer every year | SteG Art. 64(4), 64(5) |
Sources: Tax Act (SteG); Tax Ordinance (SteV, PDF).
Filing, penalties, Pillar Two and treaties
Filing, penalties, Pillar Two and treaties (SteG, SteV, GloBE-Gesetz; treaty overview state 21 October 2026).
| topic | rule | source |
|---|---|---|
| Representation | written power of attorney; a domestic representative may be required for a seat abroad | SteG Art. 90, 91(1) |
| Signature and language | signed personally; the return in German, its attachments also in English; signed confirmation that the return is complete and true | SteG Art. 94(2), (3); SteV Art. 41(2)(f), (3) |
| Filing | legal persons file electronically from tax year 2024 | SteV Art. 42a(1); Tax Administration newsletter 11/2024 |
| Deadline | set each year by the Tax Administration | SteG Art. 95 |
| Extension | six months on a reasoned written request within 30 days after the due date, provisional invoice paid; a further extension in specially justified cases | SteV Art. 42(1) to (3) |
| Procedural breach | fine up to CHF 1,000, up to CHF 10,000 in serious or repeat cases | SteG Art. 135 |
| Evasion | fine normally one times the evaded tax | SteG Art. 137 |
| Contributing to evasion | fine up to CHF 10,000, up to CHF 50,000 in serious or repeat cases | SteG Art. 139(2) |
| Pillar Two | from 1 January 2024, groups with consolidated annual revenue of at least EUR 750 million in at least two of the four preceding years; return 15 months after year end, 18 months the first time; tax year 2024 due 30 June 2026 | GloBE-Gesetz Art. 4(1); Tax Administration GloBE page |
| Treaties | 26 of 32 listed agreements in force, state 21 October 2026 | Tax Administration treaty overview |
Sources: Tax Ordinance (SteV, PDF); Tax Administration newsletter 11/2024 (PDF); Tax Administration GloBE page; Tax Administration treaty overview (PDF).
Private-asset structures: the conditions
A private-asset structure pays the minimum tax only and is not assessed (SteG Art. 64(8)). The conditions:
- No economic activity, for example only holding, managing and selling financial instruments, holdings and cash
- Shares not offered publicly, held by private investors, restrictions in the statutes
- No solicitation of investors, and no remuneration or cost reimbursement for its activity
- No actual control over the companies it holds
- Accounting kept under PGR Art. 1045 ff.
- Conditions confirmed by the taxpayer at the application and every year
The Tax Administration decides each case; nothing here is a verdict on a given structure.
Problems we solve
No published ruling timetable
No processing time is published. We plan the transaction around the decision, not around a promised date.
Old figures in circulation
Some pages still print superseded figures. We work from the current act, the background to Liechtenstein's reputation and its reforms.
Exemption limits missed
The participation exemption has limits for large holdings and lightly taxed foreign payers; the capital gains guide covers disposals.
German, signatures and electronic filing
Returns are in German, signed personally and filed electronically. We prepare the pack so the trustee can file on time.
Pillar Two for large groups
At EUR 750 million or more, a separate return and GIR notifications follow. We keep the trustee and your group tax team on one calendar.
Questions about a ruling or a PVS application?
Send us the fact pattern and we will scope it with the trustee.
Why work with us
Nadine Koller, Schaan; works in German, English and Italian. She assembles the tax return and VAT registration files that the licensed trustee reviews and files.
From our practice
The ruling questions are written before the fact pattern is final. German supporting documents are ordered at the start, not at the deadline. the PVS evidence is gathered again before each yearly confirmation.
Frequently asked questions
Who may give tax advice in Liechtenstein, and does ABB advise or represent me itself?
Tax advice for third parties is a trustee activity (TrHG Art. 2(d)), so it needs a Liechtenstein trustee permit or a lawyer's admission. ABB does not advise on tax or file with the Tax Administration itself. It collects the facts and prepares the file, and the licensed trustee advises and files. Legal advice stays with lawyers (RAG Art. 8).
What does a tax advisor in Liechtenstein cost?
ABB publishes no prices for tax advice. The cost depends on the structure and the questions to answer, and it is quoted on request after a first call. The official fee for a ruling application is fixed by ordinance, and no figure is published here.
Can tax advice guarantee that my company pays no tax?
No. A Liechtenstein company is taxed on its income at 12.5% and owes the CHF 1,800 minimum tax unless a statutory relief applies. Advice explains the rules and the lawful options. It cannot promise a tax result, and neither ABB nor the trustee does.
Can a binding ruling or private-asset-structure status be guaranteed?
No. The Tax Administration decides on a ruling application and on private-asset structure (PVS) status, and a PVS decision can be appealed within 30 days. A ruling binds the assessment while the later facts do not differ, or differ only insignificantly, from those assumed. Neither ABB nor the trustee can promise the outcome.
What are the corporate income tax rate and the minimum tax?
Corporate income tax is 12.5% of taxable net income (SteG Art. 61, 2026 text). 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. Check any figure quoted elsewhere against the current act before relying on it.
When is the minimum tax not charged?
It 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)). Outside that relief it stays due, and a private-asset structure pays that minimum only (Art. 64(8)).
What is a private-asset structure (PVS) and what are its conditions?
A PVS pays only the minimum income tax and is not assessed (SteG Art. 64(8)). It needs no economic activity, shares reserved to private investors with the restrictions in its statutes, no solicitation of investors and no control over held companies. The taxpayer confirms the conditions to the Tax Administration at the application and every year (Art. 64(4)).
How long does a binding tax ruling take and what does it cost?
No official processing time is published, and ABB gives none. The act leaves form, content, binding effect and the processing fee to a government ordinance (SteG Art. 93a(3)), and no fee figure is published here. A complete application is what the ordinance requires (SteV Art. 38a(1)).
What must a ruling application contain?
It is written and names the applicant. It describes the facts fully, sets out the concrete legal questions and gives the applicant's own tax-law assessment (SteV Art. 38a(1)). A ruling concerns a precisely defined fact pattern not yet realised (SteG Art. 93a(1)); a fact pattern already audited can get a binding commitment (Art. 93a(2)).
How long does a ruling stay binding?
It binds the assessment if 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 set time limit expires (Art. 38a(3)). The Tax Administration can also revoke or change it for the future if it proves incorrect (Art. 38a(4)).
Are dividends from foreign subsidiaries taxed in Liechtenstein?
Dividends from participations in legal persons are excluded from taxable net income (SteG Art. 48(1)(e)). Two limits apply: holdings of 25% or more where the payer deducts the distribution as an expense (Art. 48(3)(a)), and foreign payers with more than 50% passive income and light taxation (Art. 48(3)(b)); the taxpayer must prove that these conditions are not met (Art. 48(7)).
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)). The minimum taxation applies from 1 January 2024. The return is due 15 months after year end, 18 months the first time.
Who signs the annual tax return, in which language, and is it filed online?
The taxpayer signs the return personally, and the return is in German; its attachments may be in English (SteG Art. 94(2), (3); SteV Art. 41(3)). The file carries a signed confirmation that the return is complete and true (SteV Art. 41(2)(f)). Legal persons file electronically from tax year 2024. The licensed trustee prepares it under a written power of attorney.
Can I get an extension for the tax return?
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 (SteV Art. 42(1)). The provisional invoice must be paid first (Art. 42(2)). A further extension is possible in specially justified cases (Art. 42(3)).
Who carries out the tax assessment, the Tax Administration or the municipality?
The Tax Administration carries out the assessment (SteG Art. 101(1)). For taxable natural persons resident in Liechtenstein, the municipal tax office of the municipality of residence also takes part. A company or other structure deals with the Tax Administration directly.
Tell us about your tax questions
Tell us your structure and what you need answered. Pricing on request.
+423 210 0002 · Business Development department · Monday to Friday, 09:30-17:00 (CET/CEST) · Bahnhofstrasse 8, 9495 Schaan