Legal Forms of Asset Management in Liechtenstein

Nowadays, there are many ways to invest your capital to ensure the most efficient returns or to achieve the most beneficial purpose. However, not everyone is familiar with the option of asset management in Liechtenstein, which has been considered one of the best places for asset management for decades. We present two options for asset management in Liechtenstein that we have experience with – Stiftung and Liechtensteiner Treuunternehmen (Trust reg.).

What are the differences? Minimal.

STIFTUNG (Foundation) is a legal entity similar to a Czech/German foundation, established by one or more individuals through a written declaration or will, and it comes into existence by notification at the Ministry of Justice (Amt für Justiz). It can be set up for private or family purposes, with limited business capabilities. The minimum capital required for a foundation is 30,000 CHF. The statutory body of the foundation is the board, consisting of at least two members, one of whom must be a licensed trustee (Treuhänder). Beneficiaries receive distributions from the foundation and have information and control rights.

Liechtensteiner Treuunternehmen (Trust reg.) is similar to an Anglo-Saxon trust. It is established by one or more individuals or legal entities through a written declaration and is registered in the commercial register. The trust can be set up for private or family purposes and may engage in business activities without restrictions. The minimum capital for a trust is also 30,000 CHF, which can be substituted by non-cash contributions. The statutory body is the trust board. Just like in the case of a foundation, beneficiaries receive distributions from the trust and have information and control rights.

Regarding taxation, both Liechtenstein foundations and trusts are subject to corporate income tax at a rate of 12.5%, and there is no withholding tax on beneficiary payments (this does not affect the taxation of beneficiary income in the Czech Republic).

Additionally, Liechtenstein has introduced a special tax regime for foundations and trusts that qualify as private wealth structures (Privatvermögensstruktur). This regime offers tax and administrative benefits to foundations and trusts dedicated exclusively to asset management and not engaged in any active business activities, which is a basic requirement for applying this regime. The main advantage of these structures is that they pay income tax only at a flat rate, currently set at 1,800 CHF per year.

Below is a comparison of investment structures based on who makes the financial investments, specifically comparing an individual (who draws investment capital from their domestic company), a joint-stock company, and a Liechtenstein trust. The data in the table is for orientation only.

Czech Individual Czech Joint-Stock Company Liechtenstein Trust

(non-operating)

Taxation on the withdrawal of financial assets from the company 15 % X X
Taxation on dividends 15 % (possibly more depending on source jurisdiction) 15 % (possibly more depending on source jurisdiction) 15 % (possibly more depending on source jurisdiction)
Taxation on capital gains from stock investments 15% or 23%; exemption possible after 3 years of holding 21 % flat tax of 1,800 CHF / year

There are indeed a variety of asset structures. We will help you choose the most optimal one for you. SAMAK will assist you with the establishment and management of asset structures both in the Czech Republic and in Liechtenstein, as well as in setting up specific conditions for the effective management of your family assets. Therefore, please do not hesitate to contact us if you are interested in scheduling a meeting.

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