The IPRG primarily answers which law applies; it does not automatically determine the competent court or enforcement of a judgment.
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IPRG · LR 290 · LGBl. 1996 Nr. 194 · Editorial explanation · not an official translation
Liechtenstein Private International Law: IPRG for Structures and Transactions
The IPRG is in force in the LILEX consolidation effective 1 January 2015. This is an independent editorial explanation, not an official translation or the complete text; treaties, EEA law, jurisdiction and judgment recognition require separate review.
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.
Foreign law is identified and applied as the law of the relevant state; inability to establish it has separate consequences.
Nationality, domicile, habitual residence, asset location and party choice operate as different connecting factors.
A foundation, trust, company, estate or contract requires its own map of characterisation, governing law, mandatory rules and public policy.
01
Conflicts method and foreign law
The analysis begins by characterising the issue as personal status, family, succession, property, contract or non-contractual obligation. The relevant connecting rule is then selected and it is determined whether a reference reaches foreign conflicts rules or substantive law only. The IPRG provides for identifying foreign law and permits party assistance, but evidential strategy should not replace a reliable presentation of its content and currency. Public policy, mandatory rules and changes in connecting facts over time require separate attention.
02
Persons, family, succession, property and obligations
A single international structure can be governed by several legal systems at once. A natural person's status connects to nationality and place-of-life rules; family and succession questions have their own factors and limited party autonomy. Property depends on asset location and the nature of the right, while contracts require review of permissible choice, scope, form and third-party protection. An opinion should therefore separate capacity, transaction validity, title transfer, liability, succession and third-party effects rather than place them under one general governing-law clause.
03
Structures, courts and recognition
For a company, foundation or trust, the first step is to identify the entity's nature and the exact issue: internal governance, organ authority, beneficiary rights, an asset or a third-party contract. A conflicts conclusion is not an answer on international jurisdiction, interim relief, recognition or enforcement; the ZPO, EO, treaties and relevant EEA law govern those layers. The working file should show the basis of jurisdiction, valid service, content of foreign law and enforceability of the requested outcome in each state where persons or assets are located.
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.