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Liechtenstein: Private foundation funds as holding companies – a new (hybrid) tax vehicle?

The Liechtenstein private foundation (Private Stiftung) is still a well-known instrument for private estate planning in Liechtenstein, especially for foreign investors. After recent legislative changes in Liechtenstein, a foundation may adopt the form of an alternative investment fund (AIF) and therefore access fund taxation rules in Liechtenstein and abroad. This new compound of a corporate, regulatory and tax hybrid vehicle also offers interesting opportunities for setting up a financial holding company without operative functions.

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