A PVS must be a legal person that carries on no economic activity in pursuit of its purpose and satisfies every condition in Article 64 SteG.
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Art. 64 SteG · Arts. 37–38 SteV · Editorial explanation · not an official translation
Liechtenstein Private Asset Structure (PVS)
An editorial explanation of the current PVS status based on the Tax Administration page and Articles 62 and 64 SteG and 37–38 SteV. PVS is an application-based tax status subject to conditions, not a separate legal form or automatic exemption.
Editorial explanation · not an official translation
Key takeaways
This is an independently authored explanation of official materials, not an official translation or a reproduction of the complete text. The current German version, transitional provisions and the facts of the matter must be checked before reliance.
Permitted holdings include financial instruments, interests in legal persons, liquid funds and bank balances, but the PVS and connected persons must not exercise actual influence over management of a participation.
Shares or interests may not be publicly placed or exchange-traded, and investors or beneficiaries must belong to the restricted classes in Article 64(3) SteG.
The Tax Administration grants the status on application after reviewing evidence; the application is due by the end of the relevant tax year and the annual confirmation no later than twelve months after year-end.
A qualifying PVS is outside ordinary income taxation and pays only the CHF 1,800 minimum income tax under Articles 62 and 64 SteG while its conditions remain satisfied.
Failure to meet the conditions, or failure to provide confirmations after a reminder, triggers ordinary income tax for the affected years.
01
Boundary of permitted activity
Article 64 SteG links PVS status to passive administration of private wealth. A legal person may acquire, hold, administer and dispose of financial instruments, participations, liquid funds and bank balances, but must not conduct economic activity, solicit investors or receive activity-related remuneration from investors or third parties. Its constitutional documents must expressly subject it to the PVS restrictions. A label or family purpose is insufficient: the Tax Administration examines actual activities and assets.
02
Investors, participations and control
Eligible investors are limited to an individual administering private wealth, an asset structure acting exclusively for the private wealth of one or more individuals, or an intermediary acting for those investors. PVS shares or interests cannot be publicly placed or exchange-traded. Participations in operating companies are permitted only where the PVS, its equity holders and beneficiaries exercise no actual direct or indirect influence over their management. Control is therefore tested on the facts, not solely by the percentage held.
03
Application, annual control and tax
The SteV requires an application by the end of the relevant tax year and confirmations of no business activity, restricted investors, no capital solicitation or activity remuneration, and no management control over participations. The Tax Administration may inspect constitutional documents, accounts, income and asset descriptions, organ minutes, register extracts and investor confirmations. The annual confirmation is due within twelve months after year-end. Compliance produces only the CHF 1,800 minimum tax; breach or failure to confirm after a reminder leads to ordinary income taxation for the affected years.
LILEX · LLV · FMA
Official sources
This is an independently authored explanation of official materials, not an official translation or a reproduction of the complete text. The current German version, transitional provisions and the facts of the matter must be checked before reliance.
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Discuss the legal positionEditorial explanation · not an official translation. This is an independently authored explanation of official materials, not an official translation or a reproduction of the complete text. The current German version, transitional provisions and the facts of the matter must be checked before reliance.