Liechtenstein levies corporate income tax (profit tax) on resident companies' worldwide income at a flat 12.5% rate, while non-resident companies are taxed only on Liechtenstein-source income from property or a branch. All legal entities are also subject to an annual corporate minimum tax of CHF 1,800 (fully creditable against profit tax), and ultimate parent entities of qualifying multinational groups face a 15% Qualified Domestic Minimum Top-up Tax and Income Inclusion Rule under Liechtenstein's OECD Pillar Two implementation.
The tax year generally follows the company's own accounting period; the corporate minimum tax applies for tax years beginning on or after January 1, 2017.
Liechtenstein's headline corporate income tax (CIT) rate is 12.5%.
The headline personal income tax (PIT) rate is 22.4%.
The standard VAT/GST (or equivalent consumption tax) rate is 8.1%.
An individual is tax resident if their residence or habitual abode is in Liechtenstein. "Residence" means the place where a person lives with the intention of staying permanently; "habitual abode" means a stay in Liechtenstein that is no longer temporary once it continuously exceeds six months (disregarding short interruptions). A legal entity is resident if its seat or place of effective management is in Liechtenstein. Resident individuals and companies are taxed on worldwide income and wealth (Liechtenstein levies both an income tax and a wealth-linked notional-income tax); non-resident companies are taxed only on Liechtenstein-source income and any Liechtenstein permanent establishment.
Income derived from a foreign permanent establishment may be exempt from taxation in Liechtenstein under Liechtenstein's unilateral relief provisions or applicable tax treaties, provided the foreign PE is itself subject to local taxation, avoiding double taxation; the domestic permanent establishment definition broadly tracks the OECD Model, and branches of foreign companies operating in Liechtenstein are taxed on their Liechtenstein-source profits at the same 12.5% rate as resident companies, with no separate branch profits or remittance tax.
Confirmed independently across multiple authoritative sources - PwC, a Chambers and Partners Global Practice Guide, and Moore Global all state directly that Liechtenstein has no CFC legislation and has not implemented BEPS Action 3; earnings from foreign subsidiaries are not attributed back to the Liechtenstein parent or resident shareholder. Instead of a CFC-style attribution mechanism, Liechtenstein uses a narrower switch-over rule: dividends and capital gains from a foreign legal entity are exempt from Liechtenstein tax unless that foreign entity is low-taxed abroad and sustainably earns more than 50% passive income, in which case the exemption is denied and the income becomes taxable in Liechtenstein at the ordinary rate.
Liechtenstein has no thin capitalization rules (no debt-to-equity ratio). All related-party transactions, including intra-group loans, must be priced at arm's length under Liechtenstein's transfer pricing rules; for interest specifically, the Liechtenstein Tax Administration publishes safe-harbour minimum interest rates each calendar year for loans between associated companies or persons, and interest charged below the published rate can be adjusted by the tax authorities.
Liechtenstein classifies entities under its own domestic Tax Act rather than offering an elective check-the-box system, and no ATAD2-style anti-hybrid mismatch regime addressing double-deduction or deduction-without-inclusion outcomes has been identified. Liechtenstein has explicitly not implemented BEPS Action 3 and has no CFC legislation: earnings from foreign subsidiaries are not attributed to a Liechtenstein resident shareholder. Instead, Liechtenstein uses a narrower switch-over rule that denies the participation exemption (taxing the dividend or capital gain at the ordinary rate) where the foreign entity is low-taxed and sustainably earns more than 50% passive income.
No domestic FBAR-equivalent regime requires Liechtenstein residents to separately disclose foreign financial accounts. Liechtenstein is a well-established CRS participating jurisdiction and exchanges financial account information with partner tax authorities as part of its broader move toward international tax transparency standards. US persons remain independently subject to FinCEN Form 114 (FBAR) and potentially Form 8938 regardless of Liechtenstein's own rules.
Dividend income and liquidation proceeds from a foreign legal entity are generally tax-exempt for corporate investors where the participation is at least 25%, and capital gains from selling holdings above that threshold are similarly exempt, provided the dividend was not tax-deductible in the source country. The exemption is denied under the anti-abuse switch-over rule described above where more than 50% of the foreign entity's income is passive and it is subject to low taxation, a rule that has applied to participations established from 2019 and, since 2022, to participations established before 2019 as well.
In most cases, double taxation of income is avoided through the exemption method under Liechtenstein's domestic relief rules or its network of double tax treaties, rather than a standalone foreign tax credit mechanism; Liechtenstein's Private Asset Structures (passive-holding vehicles subject only to the CHF 1,800 minimum tax) are generally excluded from treaty benefits.
Liechtenstein maintains a comparatively limited but growing treaty network: 23 comprehensive double tax treaties currently in force, with Andorra, Austria, Croatia, Czech Republic, Estonia, Georgia, Germany, Guernsey, Hong Kong, Hungary, Iceland, Jersey, Lithuania, Luxembourg, Malta, Monaco, the Netherlands, Romania, San Marino, Singapore, Switzerland, the United Arab Emirates, the United Kingdom, and Uruguay. Treaties with Bahrain, Belgium, and Ireland have been negotiated but are not yet in force; treaties with Latvia and Montenegro are agreed and scheduled to take effect 1 January 2027; the treaty with Italy awaits final ratification. Liechtenstein has no comprehensive US income tax treaty, relying instead on the separate US TIEA for information exchange. Note that Private Asset Structures (Liechtenstein's passive-holding vehicle, subject only to the CHF 1,800 minimum corporate tax) are generally excluded from double tax treaty benefits.