"Relocation and transfer of registered office from Switzerland to Liechtenstein"

The text deals with the tax and legal aspects of a transfer of domicile and registered office from Switzerland to Liechtenstein using the example of Karl Jacob AG. This company is entitled to annual royalties from the sale of trademark rights. Karl Jacob, who owns the company and provides consultancy services, decides to move to Liechtenstein with his wife, as does Karl Jacob AG.

The tax analysis shows that the transfer of the company's registered office to Liechtenstein is equivalent to a liquidation and triggers exit taxation of the hidden reserves in Switzerland. However, there is controversy and criticism regarding the valuation of these reserves.

In Liechtenstein, both the company and private individuals benefit from lower tax rates and tax relief, such as the exemption of dividend distributions from acquisition tax and a moderate maximum tax burden. Exit taxation in Switzerland and potential double taxation remain challenges.

Overall, it is emphasized that the tax advantages of relocating to Liechtenstein are considerable, especially for wealthy individuals.

Topics in the publication

• Transfer of domicile
• Transfer of the registered office of companies
• Tax assessment
• License compensation agreements
• Exit taxation
• Double taxation
• Income and acquisition tax in Liechtenstein
• European Court of Justice case law
• Debt call and legal formalities: