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State Aid

State aid: New Liechtenstein tax status scheme cleared



The introduction in Liechtenstein of a new tax status entitled “Private Investment Structure” (P.I.S.) does not involve state aid, the EFTA Surveillance Authority decided today.

The P.I.S. tax status can only be granted to entities which do not engage in economic activity. Consequently, such entities do not constitute “undertakings” within the meaning of the state aid rules under the EEA Agreement. Therefore, no state aid is involved.

Under the new Liechtenstein Tax Act of 23 September 2010, entities with P.I.S. tax status essentially may only acquire, hold, administer and sell assets. This activity is limited to passively receiving income derived from the assets and excludes any commercial trading.

The new Tax Act also includes specific rules which prohibit entities with P.I.S. tax status from receiving fund management and similar fees. In addition, entities with P.I.S. tax status which hold shares in an undertaking are prevented from exercising control over that undertaking and thus engaging in economic activity. Furthermore, the owner of an entity with P.I.S. tax status cannot be an undertaking; it can only be a natural person, an entity with P.I.S. tax status or an intermediary acting on behalf of either of the former.

The Liechtenstein authorities will interpret and apply the rules on P.I.S. status strictly, based on administrative procedures involving a detailed review of each case in order to verify that no economic activity is carried out.

Based on these considerations and relevant case law, the Authority has come to the conclusion that P.I.S. tax status does not involve state aid.


For further information, please contact:

Mr. Trygve Mellvang-Berg
Press & Information Officer,
tel. (+32)(0)2 286 18 66
gsm (+32)(0) 492 900 187

Per Andreas Bjørgan,
Competition and State Aid  Department
tel. (+32)(0)2 286 18 36   

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