Liechtenstein Trust Structures for Ultra-HNW Families

Liechtenstein — a microstate of 40,000 people between Switzerland and Austria — has been a global center for trust and foundation law since 1926. The Liechtenstein Foundation (Stiftung) is one of the most powerful wealth preservation tools available to ultra-HNW families, offering flexible governance, robust asset protection, and favorable tax treatment.

The Liechtenstein Foundation (Stiftung)

A Stiftung is a self-governing legal entity with no owners or shareholders. Once assets are transferred to the foundation, they belong to the foundation — not to any individual.

Key Features

• Founder: Establishes the foundation and defines its purpose
• Foundation Council: Manages the foundation (minimum 2 members, at least 1 must be a qualified Liechtenstein resident)
• Beneficiaries: Receive distributions according to the foundation’s deed and bylaws
• No shareholders or owners — the foundation is its own entity

Asset Protection

• Assets transferred to a bona fide foundation are protected from future creditor claims after a 2-year hardening period
• The founder can retain certain rights (revocation, amendment, consent to distributions) while still achieving asset separation
• Forced heirship claims from foreign jurisdictions are generally not enforceable against Liechtenstein foundations

The Tax Structure

Foundation Tax

• Liechtenstein foundations pay a minimum annual tax of CHF 1,800 (~$2,000)
• If the foundation has taxable income (rare for pure holding foundations), corporate tax is 12.5%
• No withholding tax on distributions to beneficiaries
• No capital gains tax on the disposal of participations (participation exemption)
• No inheritance or estate tax — assets in the foundation pass to successive beneficiary classes without triggering death taxes

Personal Tax (if resident)

• Liechtenstein personal income tax: progressive up to 22.4% (including municipal surcharge)
• No capital gains tax for individuals
• Wealth tax of 0.1% of net assets per year

The Privacy

Liechtenstein does comply with international information exchange standards (CRS, OECD). However:

• Foundation registers are not publicly accessible
• Beneficiary information is held by the foundation’s trustee, not in a public register
• Information is shared only through formal treaty mechanisms upon qualified request

The Cost Structure

Component	Annual Cost
Foundation establishment	CHF 15,000-30,000
Foundation Council fees	CHF 5,000-15,000/year
Audit (if required)	CHF 5,000-10,000/year
Minimum tax	CHF 1,800/year
Legal and administrative	CHF 5,000-15,000/year
Total	CHF 30,000-70,000/year

This is a structure for families with $10M+ in assets, where the annual administration costs are trivial relative to the estate and tax planning benefits.