Liechtenstein has signed various double taxation agreements over the years in order to provide foreign investors with a suitable business and tax environment. In 1970 Liechtenstein signed a double tax treaty with Austria, as the number of Austrian investors in the Principality was rising and it imposed such measure. The agreement was renewed in 2013, at the same time as the agreement between Austria and Switzerland was amended, given the connection between the Principality and Switzerland. The Liechtenstein – Austria double taxation agreement also received an amendment in 2016.
Our company formation agents in Liechtenstein can offer information on taxation in the Principality.
Provisions in the Liechtenstein – Austria double tax treaty
The double tax treaty between Liechtenstein and Austria covers both natural persons and companies with a tax residency in one or both countries. The agreement covers the income and the capital gains taxes applied in both countries.
A special provision in the Liechtenstein – Austria double taxation agreement refers to permanent establishments of Austrian and Liechtenstein companies in the other state, as well as associated enterprises which will be taxed only in the country where they undertake commercial activities. Branch offices, factories and other types of offices are deemed permanent establishments under the treaty for the avoidance of double taxation between Austria and Liechtenstein.
Our company formation consultants can assist foreign investors who want to open a company in Liechtenstein.
The 2016 Liechtenstein – Austria double taxation convention
The latest amendment to the Liechtenstein – Austria double tax treaty brings changes related to the taxation of dividends for which a new tax rate has been agreed upon. Under the new tax treaty, the dividends paid to a company which owns at least 10% of the voting shares for a period of at least 12 months will be taxed at a 0% rate, while in other cases the tax will be 15%. Interest payments will only be taxed in the country of residence of the taxpayer.
Taxation of financial institutions
The amended double taxation treaty between Liechtenstein and Austria also provides for specific tax regulations related to financial institutions, such as banks, and those who own assets in Liechtenstein and Austrian banks.
Under the agreements, banks, trustees and asset managers will be imposed withholding taxes on earnings made in the past. Other investments incomes will also be taxed if the earning come from non-transparent foundations. The same withholding tax will be applied to the beneficiaries holding their assets in non-transparent entities.
Exchange of information under the Liechtenstein – Austria DTT
The 2016 tax treaty between Austria and Liechtenstein also provides for the exchange of tax information, according to the recommendations of the OECD. The exchange of information will be made on request of a Liechtenstein or Austrian financial institution.
The reasons why Liechtenstein signed this clause is the desire of the government of becoming a more transparent economy and thus gain the credibility of future investors.
During the last 2 years Liechtenstein obtained the highest rating from credit rating agencies thanks to its fiscal policies.
For full information on the provisions of the new double tax agreement with Austria, please feel free to contact our company formation representatives in Liechtenstein.