Liechtenstein Structures Guide

🇱🇮Liechtenstein

Trust, Stiftung &
Anstalt

Three legal instruments that separate assets from the individual owner — and why choosing between them requires analysing the family, the assets and the jurisdictions involved, not just the legal form.

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Important: General Overview — Not Legal, Tax or Succession Advice

Liechtenstein corporate law is governed by the Personen- und Gesellschaftsrecht (PGR), last consolidated as of 1 July 2026. Rules evolve. This article provides a general educational overview. Always verify current requirements with qualified Liechtenstein counsel. Octopus BFCO coordinates structure design with licensed Liechtenstein trustees and legal specialists.

Why Liechtenstein

A Jurisdiction That Took Structure Seriously in 1926

Liechtenstein is a small European state within the European Economic Area — but with its own legal system and a developed professional asset management industry. The Personen- und Gesellschaftsrecht (PGR), enacted in 1926 and regularly updated, is the central source of corporate law. The latest consolidated version incorporates amendments in force from 1 July 2026.

What distinguishes Liechtenstein is not merely the existence of trusts and private foundations — both exist in many jurisdictions. What is distinctive is the Anstalt: a hybrid organisational form with almost no direct equivalent in most other European jurisdictions.

Modern Liechtenstein cannot be treated as an anonymous offshore zone. The country operates an electronic beneficial ownership register, has AML rules, and regulates professional trustees through the Financial Market Authority (FMA). A properly structured Liechtenstein vehicle is a tool for legitimate capital management — not a device for concealment.

Three Different Legal Logics

The fundamental difference between the three forms can be summarised as follows:

  • Trust

    Built around relationships between people.

  • Stiftung

    Built around segregated assets and a purpose.

  • Anstalt

    Built around an independent legal enterprise that can simultaneously perform corporate and asset management functions.

The Three Instruments

Trust · Stiftung · Anstalt

Each structure solves the same fundamental problem — separating assets from the individual — but through entirely different legal logic.

01

Trust — Treuhänderschaft

Built around relationships between people.

The Liechtenstein trust arises when the settlor transfers assets to a trustee. The trustee becomes the legal owner but must manage them under the trust deed for the benefit of beneficiaries. The trust itself has no separate legal personality — this is what distinguishes it from the Stiftung and Anstalt.

02

Stiftung — Private Foundation

Built around segregated assets and a purpose.

The Liechtenstein Stiftung is a separate legal entity. It has no shareholders, members or holders of interests. After creation the assets legally belong to the foundation itself and must be used in accordance with its purpose. Officially described as a legally and economically independent purpose-linked asset created by the unilateral act of the founder.

03

Anstalt — Establishment

Built around an independent legal enterprise that can simultaneously perform corporate and asset functions.

The Anstalt is a separate legal entity — an organised permanent enterprise created for economic or other purposes. The law does not restrict it to non-commercial tasks. It must be registered in the Commercial Register. Its uniqueness is that it can operate in two modes simultaneously: as a commercial corporate structure, or as a structure functionally close to a family foundation. This is why it is called a hybrid of a company and a foundation.

Asset Protection

How Protection Works — and When It Doesn't

Asset protection arises not because assets become 'invisible'. It arises because after proper transfer, the asset is no longer in the direct ownership of the founder.

In a Trust

Trustee becomes legal owner.

In a Stiftung

Assets belong to the foundation.

In an Anstalt

Assets belong to the Anstalt.

A personal creditor of the founder, as a general rule, cannot automatically enforce against the assets of an independent structure simply because the founder once transferred them there. But this protection is not absolute.

When Protection Can Fail

  • Assets transferred after creditor claims arose
  • Transfer intended to evade existing obligations
  • Structure exists only on paper
  • Founder continues to use assets as personal property
  • Trustee or council is entirely nominal
  • Documents are not observed
  • Personal and structural expenses are mixed
  • Founder retained full de facto control
  • Structure used to conceal income, beneficiaries or source of funds

Risks a Properly Built Structure Can Reduce

  • Death of the asset owner
  • Incapacity
  • Family conflict
  • Division of estate
  • Fragmentation of corporate control
  • Personal claims against individual family members
  • Bankruptcy of one heir
  • Mismanagement by young beneficiaries

Succession

Inheritance Without Transferring Each Asset to Heirs

If a natural person directly owns shares, bank accounts and real estate, after death each asset may become part of the estate.

If the asset belongs to a foundation, trust or Anstalt, the founder's death does not of itself terminate the structure or change the legal owner of the asset.

What changes is not the owner of each individual object, but:

  • The composition of beneficiaries
  • The persons exercising control
  • Council members
  • The income distribution procedure
  • Holders of founder's rights

Pre-set rules can include, for example:

  • Spouse receives lifetime maintenance
  • Children receive income but cannot sell the core business
  • Management influence passes only to prepared successors
  • Capital is distributed in stages
  • Part of the profit is reinvested
  • Family company is not fragmented among dozens of heirs
  • In case of conflict, an independent council decides

Liechtenstein Law Does Not Override Foreign Succession Rules

Creating a structure in Liechtenstein does not automatically cancel compulsory inheritance shares in the country of citizenship, domicile or asset location. Foreign courts may look at when assets were transferred, whether the founder retained control, whether heirs' compulsory rights were violated, and which law governs the succession. Planning must be built simultaneously under Liechtenstein law and under the laws of all countries connected to the founder, heirs and assets.

Multi-Level Business Structuring

In practice, family structures rarely hold all operating assets directly. A typical multi-level model:

Foundation / Trust / Anstalt

↓

Holding company

↓

Operating companies in different countries

↓

Real estate, staff, contracts and commercial risks

Taxation

CHF 1,800 a Year — What It Actually Means

Ordinary Liechtenstein legal entities pay corporate income tax at 12.5%. A minimum annual tax of CHF 1,800 applies.

Privatvermögensstruktur — PVS Status

A Stiftung or Anstalt may obtain PVS status — a special tax status granted by application. If the structure meets the conditions, it pays no ordinary corporate income tax and only the minimum annual tax of CHF 1,800. The trust, as a non-legal-entity special segregated asset, may similarly be subject only to the CHF 1,800 minimum.

The core condition: no economic activity. The structure may passively hold private assets — cash, securities, portfolio, company stakes — but must not sell goods, provide services, conduct operating business or actively manage subsidiaries' commercial activities.

The CHF 1,800 Regime Applies Only at the Liechtenstein Level

  • Does not eliminate taxation of founder and beneficiaries in their countries of tax residence
  • Does not override Controlled Foreign Company (CFC) rules in other states
  • Does not exempt distributions, inheritance, gift taxes or foreign real estate taxes
  • PVS status must be obtained and confirmed annually

The statement 'a Liechtenstein foundation pays only CHF 1,800' may be accurate for the structure itself — but insufficient for assessing the overall tax burden of the family.

Which to Choose

Trust, Stiftung or Anstalt — Matching Form to Objective

Trust

Maximum distribution flexibility; family familiar with Anglo-Saxon trust model; professional trustee needed; discretionary multi-generational support; no separate legal entity required.

Stiftung

Capital must belong to an independent long-term structure; primary task is succession; family business to be kept intact; clearly fixed purpose; no owners or interests inside.

Anstalt

Independent legal personality needed; commercial activity or business ownership required; more corporate model than foundation; founder's rights with beneficiary provisions; enterprise + holding + asset planning in one form.

12 Questions Before Creating Any Structure

  1. 01Where does the founder live and what is their tax residence?
  2. 02Where do the beneficiaries live?
  3. 03In which countries are the assets?
  4. 04Is there real estate?
  5. 05Is an operating business needed?
  6. 06Must the founder retain control?
  7. 07What rights should the spouse, children and future generations get?
  8. 08Are there compulsory heirs?
  9. 09What specific risks require protection?
  10. 10How will the structure be financed and bear expenses?
  11. 11Who will make decisions after the founder's death?
  12. 12How will tax authorities in other countries qualify the structure?

The same Liechtenstein structure may be recognised as an independent foundation in one country, a transparent entity in another and a controlled foreign company in a third. Legal form is only half the construction. The other half is its international tax and succession qualification.

Comparison

Quick Comparison

CriterionTrustStiftungAnstalt
Legal entityNoYesYes
Asset ownershipTrusteeFoundationAnstalt
ShareholdersNoneNoneUsually none (classic)
Governing bodyTrusteeFoundation councilBoard / admin council
Basis of controlTrust deed & trustee powersPurpose & documentsFounder's rights & charter
Business activityUsually via companiesUsually via subsidiariesDirectly or as holding
Succession planningVery flexiblePrimary functionPossible, esp. memberless model
Unique featureFiduciary relationshipAssets belong to purposeHybrid: enterprise + foundation

FAQ

Frequently Asked Questions

Start with the Objective

Tell us what you need to protect, preserve or pass on.

Octopus BFCO coordinates Liechtenstein structure design together with tax structuring, succession planning, holding architecture, banking and international compliance — so your asset strategy is aligned across every jurisdiction where you, your family and your assets are present.

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