Alternatives to and distinction of the Liechtenstein Foundation

The following structures are also used in Liechtenstein as an alternative to the Lichtenstein Foundation for asset management, asset succession and asset protection:

For a non-binding enquiry, please contact us by phone or e-mail or use the contact form at the bottom of this page.

Fiduciary trust    

The fiduciary trust (also known as a trust transaction or fiduciary legal transaction) is characterised by the fact that it transfers more rights to the trustee externally than he is allowed to exercise internally according to the agreement with the trustor.

The fiduciary relationship can serve the interests of the fiduciary (so-called self-interested fiduciary, e.g. transfer of ownership by way of security) or the interests of the settlor (so-called third-party fiduciary, e.g. administrative fiduciary or debt collection assignment).

In a genuine fiduciary relationship, the items or rights (the trust property) are transferred to the trustee in full. Economically, however, the trust property belongs

to the assets of the settlor. In this case, the trustee acts in his own name, but at least partially in the interest of a third party.

In the case of a non-genuine trust relationship, the settlor remains the owner of the property or holder of the rights. However, the trustee is authorised either to dispose of the trust property in his own name or to act as the settlor’s representative.

A fiduciary transaction can be concluded openly (recognisable to everyone) or concealed. A concealed fiduciary transaction is also recognised and effective; in particular, it is not a sham transaction, as the legal effects are intentional. The situation is different if the parties involved believe that the effects would also occur through a fictitious transaction, for example through a transfer of ownership as a sham in order to save an asset from being seized by creditors.

Liechtenstein Trust

For the legal structure and practical application of the Liechtenstein Trust, see our explanations at

Liechtenstein Establishment

For the legal structure and practical application of the Liechtenstein Establishment, see our explanations at

Liechtenstein trust company (trust reg)

For the legal structure and practical application of the trust reg, see our explanations at

English trust (Anglo-American trust) Common law trust

Trusts can be established and registered in Liechtenstein under English/Anglo-American trust law.

The definition of an English trust corresponds to that of the Hague Trust Convention.

For the legal structure and practical application, see: > trust law > vn-ber-d > konso > pdf

Note: The English authors / commentators and the English courts are still unable to establish their own definition of the English trust due to the complexity of the trust and ultimately follow the definition of the Hague Trust Convention.

Offshore Foundation

Many offshore jurisdictions do not comply with OECD standards (e.g. Panama, Marshall Islands, Caiman Islands, British Virgin Islands, Anguilla, etc.). These countries have not acceded to the international agreements (e.g. on the exchange of information).

Practical tip: Offshore foundations can be domiciled in Liechtenstein. Untaxed offshore assets can be transferred to a Liechtenstein foundation provided that a transfer tax of 12.5% is paid in Liechtenstein.

Caution with offshore foundationsDisadvantages!  Foundations established under the laws of an offshore jurisdiction are usually not recognised under legal and tax law in the settlor’s country of domicile (black lists/red lists), with the result that the foundation’s assets continue to be attributed to the founder. The foundation is also often regarded as non-existent in the beneficiary’s country of domicile, with negative consequences for the beneficiary. The offshore foundation jurisdictions often differ in individual cases in terms of the structure of asset protection and the recognition of foreign compulsory portions.

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