Beruflich Dokumente
Kultur Dokumente
Allgemeines
Treuunternehmen
since 1929
Author
Roger Frick
1. Summary
The aim of the amendments to Liechtensteins tax law, which took effect on
1January 2011, is to modernise the
present legal order with regard to taxation
by taking into account international developments. This should ensure that Liechtenstein continues to have a tax system
which is attractive both nationally and
internationally in future, while complying
with the European requirements (especially
fundamental freedoms and the regulations prohibiting state aid, including ringfencing).
Under the new legislation, legal persons
which are taxable in Liechtenstein and
engaged in economic activity are only
subject to corporate income tax and the
supplementary tax on gains from the
transfer of real property. No capital tax
is levied. From now on, corporate income
tax at a uniform rate of 12.5% applies to a
companys net income/profit, irrespective
of the size of that profit and its distribution. Income and capital gains from parti
cipating interests are exempt, and there is
no time limit on the use of losses carried
forward. Furthermore, an equity capital
interest deduction has been introduced.
Other innovations contained in the Tax
The structuring and protection of assets, family office, inheritance and succession planning,
i nternational tax advice and planning, legal advice, trusts, foundations and companies, processing
of international business transactions, bank selection, Focus on: Liechtensteins new tax law.
I nvestment funds and insurance, accounting and annual f inancial statements, change of residence,
the structuring and protection of assets, family office, inheritance and succession planning, international tax advice and planning, legal advice, trusts, foundations and companies, processing of
international business transactions, bank selection, investment funds and insurance, accounting
and annual financial statements, change of residence, the structuring and protection of assets,
2. Basic information
on the tax amount
2
3
3.1 Examples
Total assets
Variant 1
Variant 2
Variant 3
Variant 4
300'000
250'000
400'000
200'000
500'000
150'000
150'000
300'000
Debts
500'000
500'000
250'000
200'000
500'000 1'000'000
500'000
1'000'000
75'000
65'000
175'000
163'000
4 % interest on debt
(used for foreign real property)
-10'000
-8'000
50'000
50'000
50'000
50'000
8'100
6'750
10'800
5'400
-25'000
-25'000
-25'000
-25'000
700'000
750'000
600'000
800'000
500'000
150'000
150'000
300'000
250'000
300'000
700'000
500'000
600'000
500'000
75'000
65'000
175'000
163'000
50'000
50'000
50'000
50'000
Management expense
(for managing participating
interests)
-25'000
-25'000
-25'000
-25'000
100'000
90'000
200'000
188'000
4 % deduction of equity
interest:
- on 200000
+ 50'000
- on 350000
+ 45'000
- on 450000
+100'000
- on 200000
+ 94'000
-10'000
-15'800
-22'000
-11'760
Pre-tax profit
90'000
74'200
178'000
176'240
Tax levied on
40'000
24'200
128'000
126'240
5'000
3'025
16'000
15'780
4. Taxable and
tax-exempt income
Taxable net income consists of the totality
of income minus justified business expenditure. In particular, taxable net income
includes:
a) The balance of the profit and loss
account;
b) All parts of the trading result segregated
for calculation of the balance which
are not used to meet justified business
expenses;
c) Depreciation, amortisation, writedowns and provisions not justified for
business purposes;
d) Transfers to the reserve funds, not justified for business purposes, except any
4
5
5. Tax liability of
Establishments, Trust
Enterprises, Aktien
gesellschaften,
GmbHs and foundations (= legal persons)
The distinction known to date between
a non-commercial business (e.g. holding
activity) and a commercial business (e.g.
6
7
ATU Bulletin is published in German, French, English and Italian. ATU Bulletin is an occasional publication of Allgemeines Treuunternehmen, Vaduz. The content serves only to provide general information and is no substitute for legal advice.
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