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State Aid

State aid: Recovery of tax exemptions to Liechtenstein investment companies


Today, the EFTA Surveillance Authority decided that certain tax exemptions applicable in Liechtenstein to investment companies (Anlagegesellschaften) until 2006 constitute state aid. This aid is incompatible with the EEA Agreement and must be re-paid to the Liechtenstein Government.

Liechtenstein law defines investment undertakings as capital raised from the public for the purpose of a collective capital investment. These assets are invested and managed for the collective account of the individual investors. Under Liechtenstein law, the management of these assets can be undertaken by investment funds (Anlagefonds) or investment companies (Anlagegesellschaften). Between 1996 and mid 2006, no income tax was levied for the management activities of investment companies. Capital tax was set at 1‰ instead of the generally applicable 2‰ and reduced further for any capital exceeding CHF 2 million. Further, no coupon tax was levied on the coupons of securities (or documents equal to securities) issued by investment companies. The coupon tax applies to companies the capital of which is divided into shares, as for example companies limited by shares and companies with limited liability.

In today's decision, the Authority concluded that such favourable treatment provided investment companies (Anlagegesellschaften) with an advantage that was unavailable to other companies in a similar position. The decision only relates to the taxation of the management activities of the investment companies and not to the assets managed by them.

A non-confidential version of the Authority's Decision will shortly be published on the Authority's website:


For further information, please contact:

Mr. Per Andreas Bjørgan
Competition and State Aid Directorate
Tel: (+32)(0)2 286 18 36,


Ms. Maria J. Segura Catalán
Deputy Director
Competition and State Aid Directorate
Tel: (+32)(0)2 286 18 53

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