Liechtenstein: Offshore Legal and Tax Regimes
Prior to the new Tax Act, the following rules applied:
'Offshore', ie low-tax, activity in Liechtenstein is possible only through the various specialised forms and statuses listed above. Broadly speaking, commercial activity (ie non-investment activity) is not permitted within Liechtenstein to any of the 'offshore' entities.
The 'holding' entity is not limited as to where it holds assets, and can therefore operate within Liechtenstein as long as it sticks to holding activities.
The 'domiciliary' entity is limited to external trading operations, but is permitted certain internal activities, as explained in Offshore Business Sectors.
The establishment (Anstalt) can operate freely within Liechtenstein on an exempt basis as long as it sticks to (non-commercial) holding and investment-type operations.
The foundation (Stiftung) and the Trust are not limited from a tax point of view as regards holding and investment activities, and can carry these out in Liechtenstein as well as outside.