Family office in LiechtensteinOverview
Liechtenstein has no dedicated family office statute. Whether a family office needs a licence depends on what it does and for whom. Trustee services carried out commercially, that is independently, regularly and for remuneration, require an FMA licence under the Trustees Act (TrHG), and securities services such as portfolio management or investment advice for third parties require a licence under the Asset Management Act (VVG). Article 2(2) of the VVG excludes, among others, persons who provide these services only to their parent company, subsidiaries or sister companies, and persons acting only within a board mandate of a legal entity or trusteeship. A single-family office that manages its own family's holdings from within the family group can therefore often operate without a licence. A multi-family office offering the same services to unrelated families cannot.
The centre of most Liechtenstein family structures is the private-benefit foundation (Stiftung) under Art. 552 of the Persons and Companies Act (PGR), substantially revised with effect from 1 April 2009. The foundation has legal personality and no owners; the founder sets its purpose and beneficiaries, may reserve rights of revocation or amendment, and its minimum capital is CHF 30,000 (or the EUR or USD equivalent). Family foundations need not be entered in the commercial register: they may instead be deposited with the Office of Justice with limited information. The foundation council must include a person qualified under Art. 180a PGR, usually a licensed Liechtenstein trustee, which gives the structure a regulated local guardian. Protectors, family councils and investment committees are commonly added in the by-laws.
Trusts under Art. 897–932 PGR, the establishment (Anstalt) and the trust enterprise give further options, alongside AG and GmbH holding companies and alternative investment funds under the AIFM Act. The 2026 trust reform (LGBl. 2026 Nr. 12), in force since 1 July 2026, now classifies trusts as charitable or private-benefit. Private-benefit trusts must name at least one information holder and a successor, and existing private trusts have until 31 December 2027 to comply. Charitable trusts must be registered by 31 December 2026 and are supervised by the renamed Foundation and Trust Supervisory Authority (STIFTA).
Taxation is moderate and stable. Companies and foundations pay 12.5% corporate income tax with a CHF 1,800 minimum, a participation exemption for dividends and gains and a 4% notional interest deduction on modified equity. Liechtenstein levies no withholding tax on dividends, interest or royalties and no inheritance or gift tax. A foundation or Anstalt that only holds and manages private assets passively can apply for private asset structure (PVS) status: it then pays only the CHF 1,800 minimum tax and files no tax return, but cannot use double tax treaties. Privacy is protected but not absolute. Beneficial owners are recorded in the VwbP register, which third parties can see only on showing a legitimate interest, as the EFTA Court confirmed on 7 May 2025.
Key benefits
- Foundation law tested over a century and modernised in 2009, with flexible founder's rights, by-laws, protectors and family governance bodies
- EEA membership: Liechtenstein asset managers, AIFMs and funds can use EU passports, and the country applies EU financial and AML law
- Swiss franc and customs union with Switzerland, which supports Swiss-Liechtenstein combined structures
- PVS status for passive private wealth vehicles: CHF 1,800 annual minimum tax and no tax return
- No inheritance or gift tax and no withholding tax on dividends, interest or royalties
- Regulated local guardianship: Art. 180a PGR members and FMA-licensed trustees bring professional oversight to family structures
- Measured privacy: deposit instead of registration for family foundations, and beneficial-owner data available to third parties only with a legitimate interest
Requirements
- Activity test: services offered commercially to third parties (independently, regularly and for remuneration) need an FMA licence under the TrHG for trustee work or under the VVG for portfolio management and investment advice
- Exemptions to confirm case by case: Art. 2(2) VVG excludes services provided only within the group (parent, subsidiaries, sister companies) and services provided only within a board mandate of a legal entity or trusteeship
- Licensed trustees: training, at least two years' practical experience, the trustee examination, good repute, a Liechtenstein business premises and professional liability insurance of at least CHF 1 million per claim and CHF 2 million a year
- Asset management company under the VVG: initial capital of EUR 75,000 fully paid in, Liechtenstein seat and head office, at least two board members and two managers, a qualified manager with three years' experience, compliance, risk management and AML functions, a recognised auditor and a three-year business plan
- Foundations and Anstalten: minimum capital of CHF 30,000 and at least one council or board member qualified under Art. 180a PGR; registration or deposit with the Office of Justice
- Private-benefit trusts: at least one information holder and a successor named in the trust documents; existing trusts to comply by 31 December 2027
- Beneficial owners filed with the VwbP register within 30 days of formation, registration or any change; fines of up to CHF 200,000 for breaches
- AML/CFT under the Due Diligence Act (SPG): identification of contracting parties and beneficial owners, source-of-wealth checks, risk-based monitoring and reporting to the FIU
- CRS and FATCA classification and annual reporting through the Liechtenstein tax administration; PVS status reviewed periodically by the tax administration
- PVS conditions: no commercial activity, passive holding of bankable assets and participations only, no actual control over portfolio companies, no public placement of interests, and the restriction stated in the articles
Structure designs
Family foundation (Stiftung) as the succession anchor
Minimum capital CHF 30,000
Holds the family's wealth across generations, with purpose, beneficiary rules and governance set out in the deed and by-laws. Suits families who want continuity independent of any one heir and a regulated local council.
Foundation with PVS status
CHF 1,800 annual minimum tax
For portfolios of bankable assets and passive participations. Low compliance burden and no tax return, but no treaty access and no active management of portfolio companies.
Foundation above an operating or investment holding
The foundation owns an AG, GmbH or foreign holding that runs operating companies, real estate or private equity at normal tax rates, keeping treaty access where it is needed and separating control from economic benefit.
Private-benefit trust or trust enterprise
For families from common-law backgrounds or with US or UK connections who prefer a trust. Since 1 July 2026 an information holder and successor must be named; trust deeds may be deposited instead of registered.
Licensed multi-family office (trust company or VVG firm)
VVG initial capital EUR 75,000
For independent offices serving several families, combining FMA-licensed trustee services with portfolio management or investment advice, and the option of EEA passporting.
Liechtenstein layer with a Swiss or Luxembourg office
Succession and asset-protection layer in Liechtenstein, family office staff and investment team in Switzerland, and EU fund or holding vehicles in Luxembourg, each with its own regulatory and tax analysis.
Step-by-step process
- 1
Objectives and family mapping
Establish who the family members are, where they are tax resident, which assets will be contributed and what governance and succession outcomes are wanted. Residence-country tax treatment of foundations and trusts is often the deciding factor.
- 2
Licensing perimeter analysis
Decide whether the office will serve only its own family group or third parties, and whether trustee or asset management services will be provided, so the TrHG and VVG position is settled before staff are hired.
- 3
Design the foundation or trust
Draft the foundation deed and by-laws or trust deed: purpose, beneficiaries, founder's reserved rights, protector, family council, investment committee, information holder and successor.
- 4
KYC and formation
The Art. 180a council member or trustee completes due diligence under the SPG. The capital is paid in, the foundation is registered or deposited with the Office of Justice and beneficial owners are filed with the VwbP register within 30 days.
- 5
Tax status
Apply for PVS status where the structure qualifies, or register for ordinary corporate tax, and set up CRS and FATCA classification with the custodian banks.
- 6
Licences and operations
Where a multi-family office or asset manager is planned, file the FMA application (initial response usually within about three weeks of complete documents, decision within six months), lease premises and appoint auditors.
- 7
Ongoing governance
Hold council and committee meetings, keep the beneficiary register and letters of wishes current, update the VwbP register within 30 days of changes, and review the structure when family members change residence.
Typical documents
- Certified passports and proof of residential address for the founder, council members, protectors and beneficiaries
- Detailed source-of-wealth report with evidence (sale agreements, audited accounts, inheritance or gift documents)
- Bank reference letters and current bank statements for the assets to be contributed
- Family tree and chart of the existing holdings, trusts and foundations
- Draft foundation deed and by-laws, or trust deed and any supplementary deed
- Letter of wishes and protector or family council terms
- Declarations of tax residence and US-person status for CRS and FATCA
- For a VVG licence: FMA forms, three-year business plan, CVs, criminal record extracts, organisation chart, AML and compliance manuals and auditor's acceptance letter
- Articles stating the PVS restriction and the PVS application, where that status is sought
How Legal Wealth helps
Legal Wealth helps the family decide whether a Liechtenstein foundation, trust or licensed office fits its goals, and how it should sit alongside holding, investment and residence arrangements elsewhere. We work with licensed Liechtenstein trustees and counsel to draft governance that reflects the family's values, prepare a thorough source-of-wealth file, confirm the licensing perimeter and tax status before formation, and test the structure against the tax rules of each family member's country of residence. Our approach is discreet and compliance-first, with succession and long-term continuity at the centre.
Enquire with Legal WealthFrequently asked questions
Does a single-family office in Liechtenstein need an FMA licence?
Usually not if it serves only its own family group. The VVG excludes services provided only to the parent company, subsidiaries or sister companies, and the Trustees Act applies only to activity carried out commercially for third parties. The analysis depends on the exact structure and fee arrangements, so it should be confirmed before the office starts operating.
What is a PVS and who can use it?
A private asset structure (PVS) is a tax status for foundations, Anstalten and similar entities that only hold and manage private assets passively. It pays only the CHF 1,800 annual minimum tax and files no tax return. It may not carry on commercial activity, exert actual control over companies it holds or place its interests publicly, and it cannot use double tax treaties.
Does a Liechtenstein foundation have to be publicly registered?
Private-benefit family foundations may be deposited with the Office of Justice instead of being entered in the commercial register, with limited data filed. Their beneficial owners must still be recorded in the VwbP register, which third parties may see only if they show a legitimate interest.
What changed with the 2026 trust reform?
From 1 July 2026 (LGBl. 2026 Nr. 12), trusts are classified as charitable or private-benefit. Private-benefit trusts must name at least one information holder and a successor; existing ones have until 31 December 2027. Charitable trusts must be registered in the commercial register by 31 December 2026 and are supervised by STIFTA.
Can the family move to Liechtenstein with the structure?
Not easily. Liechtenstein has no investor residence programme and its residence permits are tightly controlled: for example, only 28 permits for employed EEA citizens are allocated by draw each year. Families usually live in Switzerland, the EU or elsewhere and keep the structure in Liechtenstein.
Will a foundation protect assets from future claims?
A properly funded foundation separates assets from the founder's personal estate, but transfers can still be challenged by creditors or heirs under Liechtenstein and foreign law, and residence-country tax rules may look through the structure. Asset protection depends on timing, solvency at the time of transfer and genuine independence of the council.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
Sources
- FMA Liechtenstein – Guideline 2017/1 on founding an asset management company
- Gesetze.li – Vermögensverwaltungsgesetz (VVG), consolidated version
- Gesetze.li – Treuhändergesetz (TrHG), consolidated version
- Amt für Justiz – Newsletter 2026/03 on the trust law reform (LGBl. 2026 Nr. 12)
- EFTA Court – Joined Cases E-1/24 and E-7/24 on access to the beneficial ownership register
- Chambers – Corporate Tax 2026: Liechtenstein
