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State Aid

PR(08)60: The Authority opens investigation regarding taxation of captive insurance companies in Liechtenstein


The EFTA Surveillance Authority has today decided to open the formal investigation procedure regarding taxation of captive insurance companies in Liechtenstein.

In general, captive insurance companies provide various kinds of insurance services to a limited and defined group of entities seeking insurance coverage and not to the public at large. They are in this sense “captive”. A large corporation may for example establish such a company to cover insurance needs for itself and its subsidiaries.

Captive insurance companies in Liechtenstein have been fully exempted from the regular business income tax since 1998, and they pay only half or less of the normal capital tax levied upon undertakings. They are also exempted from collecting a special coupon tax on distributed dividends.

The Authority has assessed these tax rules in the light of the state aid rules of the EEA Agreement and come to the preliminary conclusion that these exemptions constitute state aid within the meaning of the EEA Agreement.

The Authority has also doubts that these measures can be regarded as compatible with the EEA Agreement.

Liechtenstein authorities and third parties will be called on to submit their comments before a final decision will be taken.

A non-confidential version of the Decision will be published in the register of state aid decisions at the Authority’s website, normally within a month from the date of the Decision.

For further information, please contact:

Amund Utne
Competition and State Aid Directorate
Tel: (+32)(0)2 286 18 50, or

Inge Hausken Thygesen
Press & Information Officer
Legal and executive Affairs Directorate
Tel: (+32)(0)2 286 18 66 or (+32)(0)475 81 37 59


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