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Holding and Offshore Companies

Essential for the practice, in particular with regard to the taxation of a company, is the distinction between holding and offshore companies and other companies.
Holding companies are all legal entities entered in the public register and non-registered foundations, whose purpose exclusively or mainly serves asset management, in the investment or permanent management of investments in other undertakings.

Offshore companies are all legal entities entered in the public register, which only have their registered seat in Liechtenstein with or without maintaining an office and do not exercise any business or commercial activity there.

Taxes of the holding and offshore companies

Besides the company law the very liberally designed fiscal law is also decisive for the success of the principality of Liechtenstein as a financial centre.
Offshore companies of any legal form (thus AG [Aktiengesellschaft – Joint stock company], institution, foundation, etc.) and trust assets are principally exempted from all tax on assets and earnings or income tax and merely have to pay an annual capital tax in the amount of 0.1% from the deposited capital, at least CHF 1,000.-.
With the foundation the tax rate is reduced to 0.075% with capital of more than CHF 2m and to 0.05% with capital of more than CHF 10m. In addition, there are principally no other tax burdens. In particular distributions to persons with foreign domicile in the principality of Liechtenstein are generally not subject to any tax obligation.

Companies with capital broken down into shares such as in particular AGs and the GmbH [Private Limited Company] additionally have to pay a coupon tax in the amount of 4% on dividend payments

 




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