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Aktiengesellschaft (Corporation)


Tax residency – Companies registered in Liechtenstein or its place of effective management in Liechtenstein are deemed to be residents for tax purposes.

Basis – Corporate income tax is levied on worldwide profits. However, profits derived from foreign branches or permanent establishments, foreign real properties and profits undistributed by foreign subsidiaries may not be subject to taxation.

Tax rate – All companies are subject to a corporate tax of 12.5%.

A global minimum corporate tax of 15% would apply to a parent entity of a group with consolidated revenues of EUR 750 million or higher in the preceding two tax years in line with OECD’s Pillar 2 efforts.

An annual corporate minimum tax of 1,800 CHF to companies whose total assets have been CHF 500,000 or greater during the previous three years.

Capital gains – Capital gains from the disposal of shares are not subject to corporate taxes, unless more than 50% of the total income of the underlying legal entity consists of passive income and its taxable income is subject, directly or indirectly, to low taxation

Capital gains derived from the sale local properties are taxed separately under a real estate property tax of 24%

Dividends – Dividends received are usually tax-exempt, unless more than 50% of the total income of the paying entity consists of passive income and its taxable income is subject, directly or indirectly, to low taxation

Interests – Interests are subject to corporate income tax.

Royalties – Royalties are subject to corporate income tax.

Foreign-source income – Foreign-source income is taxable at standard rates, except dividend income, foreign real estate capital gains and income from foreign P.E. and branches.

Withholding taxes – There are no withholding taxes on dividends, interests, royalties, and fees paid to non-residents.

Losses – Losses arising from taxable income may be carried forward indefinitely. Carryback of losses is not allowed.

Inventory - Inventory may be valued at the lower of acquisition/production costs or market value. To determine costs are allowed First in first out (FIFO) or average cost methods.

Anti-avoidance rules – Transactions between related parties must be carried out on arm’s length terms. Transfer pricing documentation must be prepared by large companies. If a company exceeds at least two of the following three criteria, it qualifies as a large company (based on Liechtenstein company law):

  • Total assets of CHF 25.9 million.
  • Net revenue of CHF 51.8 million.
  • Annual average of 250 full time employees.

Small companies are not required to prepare transfer pricing documentation.

There are no thin capitalization rules, nor controlled foreign company regulations. However, abusive tax structures may be disregarded if there are no economic or other substantial reasons for such tax structure.

Labor taxes – Employers and resident employees are required to make contributions to several social security insurance funds:

Old age, survivors’, and disability insurance (9.3%, 4.75% by the employer and 4.55% by the employee); Family compensation fund (1.9% by the employer); Unemployment insurance/supplementary unemployment insurance (1%, 0.5% by the employer and 0.5% by the employee); Occupational accident insurance (0.1% by the employer); Occupational pension scheme (depending on pension plan)

Tax credits and incentives – There are tax exemptions for entities that have an irrevocable charitable, cultural, or ideal purpose without commercial activity, as well as for dividend income and capital gains on participations.

Private Asset Structures may enjoy tax exemptions and are only subject to a minimum tax of CHF 1,800 per annum. To be eligible as a Private Asset Structure, the company must not conduct any economic activity, and its activity should be limited to acquiring, holding, administrating, and selling financial instruments according to the Liechtenstein assets management law as well as cash and bank accounts. Participations may only be held if it can be proved that the shareholders or beneficiaries have no influence on the administration of this company.

There is also a Notional Interest Deduction on Equity, which is a standardised deduction for interest on equity based on the multiplication of the modified equity by the interest rate.

Personal income tax – An individual is deemed to be tax resident in Liechtenstein, if he or she resides or intends to stay in Liechtenstein permanently.

Resident individuals are taxed on their worldwide income, except for profits from, and net wealth in, foreign businesses, foreign branches and foreign immovable property.

Tax rates are progressive up to 8%. There are municipal taxes, which are multiplies that range from 1.5 to 2.5.

Capital gains on movable assets are tax-exempt. Capital Gains derived from local real estate is subject to a Real Estate Profit Tax of 24%.

Other taxes – The sale and import of goods and services are subject to V.A.T. at a standard rate of 8.1%. Reduced rates and exemptions may apply.

A stamp tax is levied on the transfer of securities, tax rate is 0.15% for Swiss and Liechtenstein securities and 0.3% if is issued by non-resident.

A capital duty of 1% is levied on the issuance and increase of the equity of Liechtenstein corporations. However, the first CHF 1,000,000 of capital is exempt from capital duty.

  • Offshore Income Tax Exemption
  • Offshore capital gains tax exemption
  • Offshore dividends tax exemption
  • CFC Rules
  • Thin Capitalisation Rules
  • Patent Box
  • Tax Incentives & Credits
  • Property Tax
  • Wealth tax
  • Estate inheritance tax
  • Transfer tax
  • Capital duties
  • 12.5% Offshore Income Tax Rate
  • 12.5% Corporate Tax Rate
  • 12.5% Capital Gains Tax Rate
  • 0% Dividends Received
  • 0% Dividends Withholding Tax Rate
  • 0% Interests Withholding Tax Rate
  • 0% Royalties Withholding Tax Rate
  • 0 Losses carryback (years)
  • Indefinitely Losses carryforward (years)
  • FIFOAverage cost Inventory methods permitted
  • 5.00% Social Security Employee
  • 7.25% Social Security Employer
  • 28% Personal Income Tax Rate
  • 8.1% VAT Rate
  • 37 Tax Treaties

Country details

d e - L I

The Principality of Liechtenstein is a small German-speaking landlocked state of alpine Europe that borders with Switzerland to the west and Austria to the east.

It is an enclave that, along with Switzerland, is not part of the European Union, but is part of the Schengen Area.

Its international relations are coordinated with Switzerland (the state with whom it delegates its military defense).

It has an area of just over 160 sq. km and it is inhabited by about 37,000 people. The capital is Vaduz and the most populated city is Schaan.

Liechtenstein is the fourth smallest country in Europe, after Vatican City, Monaco, and San Marino. Its resident population is composed of about a third of foreigners, mainly Germans, Austrians, Swiss, and Italians.

Liechtenstein is a constitutional monarchy, headed by the prince, or Fürst. The sovereignty of the state is shared between the prince and the citizens, who choose a parliament. The parliament of Liechtenstein, the Landtag, is composed of 25 representatives chosen by the people. A five-member chamber is responsible for daily political affairs.

The country has an economic union with Switzerland and uses the Swiss franc as the national currency, although it had its own currency, the Liechtenstein franc.

Liechtenstein is a member of the European Economic Area (an organization that acts as a bridge between the European Free Trade Association (EFTA) and the European Union) since May 1995.

Its economy, despite its small size and scarcity of natural resources, is highly industrialized, free-enterprise oriented and has the third highest per capita income in the world, after Qatar and Luxembourg.

Its economic bases are industrial exports, tourism, and financial services.

Industries include electronics, textiles, precision instruments, metal manufacturing, power tools, anchor bolts, calculators, pharmaceuticals, and food products.

It has an important financial center, specialized in financial services for foreign entities and wealth management for non-resident individuals.

Low business taxes and very advantageous incorporation laws have led to a significant number of multinational companies to establish nominal offices in Liechtenstein.

Regarding the primary sector, it produces wheat, barley, corn, potatoes, dairy products, livestock, and wine.

Tax treaties

Country Type Date Signed
Finland TIEA 2010-12-17
Denmark TIEA 2010-12-17
France TIEA 2009-09-22
Germany TIEA 2009-09-02
United Kingdom TIEA 2009-08-11
Antigua and Barbuda TIEA 2009-11-24
Singapore DTC  2013-06-27
Ireland TIEA 2009-10-13
Japan TIEA 2012-07-05
Luxembourg DTC  2009-08-26
Iceland TIEA 2010-12-17
Guernsey DTC  2014-06-11
India TIEA 2013-03-28
Greenland TIEA 2010-12-17
Italy TIEA 2015-02-26
Switzerland DTC  1995-06-22
Canada TIEA 2013-01-31
Hong Kong, China DTC  2010-08-12
Czech Republic DTC  2014-09-25
Faroe Islands TIEA 2010-12-17
Australia TIEA 2011-06-21
Sweden TIEA 2010-12-17
China TIEA 2014-01-27
San Marino DTC  2009-09-23
Uruguay DTC  2010-10-18
Austria DTC  1969-11-05
Malta DTC  2013-09-27
Norway TIEA 2010-12-17
Mexico TIEA 2013-04-08
South Africa TIEA 2013-12-06
Netherlands TIEA 2009-11-10
Andorra TIEA 2009-09-18
Monaco TIEA 2009-09-21
Saint Vincent and the Grenadines TIEA 2009-10-02
Saint Kitts and Nevis TIEA 2009-12-11
Belgium TIEA 2009-11-10
United States TIEA 2008-12-08

Tax treaties Map



We can help you incorporate a Aktiengesellschaft (Corporation) in Liechtenstein.
Please, contact us to request a free, no obligation consultation.


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