Estonian Company Run from Liechtenstein: Tax Rules

Some entrepreneurs in Liechtenstein form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from Liechtenstein. That works, but Liechtenstein's income tax on legal persons does not look only at where a company was founded: a legal person whose seat or place of actual management is in Liechtenstein is taxed there without limit, on all its income. Liechtenstein has no rule that adds a foreign company's retained profit to its owner's income, but a dividend from a low-taxed foreign company with mostly passive income loses its exemption. And the Estonia–Liechtenstein tax treaty, in force since December 2025, leaves a company resident in both countries to an agreement between the two tax authorities. This guide sets out these rules with the official texts, and what we do on the Estonian side.

The guide is general information, not tax advice. How your company and you are taxed depends on the facts of your case; ask a Liechtenstein tax adviser (Steuerberater) before you form or buy the company. We read the Tax Act (Steuergesetz, SteG, LGBl. 2010 Nr. 340) in the consolidated version of 1 July 2026 published in Lilex, the Liechtenstein law database, and the Estonia–Liechtenstein tax treaty in Riigi Teataja, on 24 October 2026; the English wording of the Tax Act below is our translation.

In Estonia: an Estonian company is Estonian

A company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6). Its profit is taxed when it is distributed, not while it stays in the company — the guide how Estonia taxes company profit explains the rule. The company keeps its Estonian duties wherever its owners live: accounts, an annual report to the commercial register and, if its address is abroad, a contact person in Estonia.

In Liechtenstein: the company side

Seat or place of actual management. Legal persons are taxable without limit on all their income if their seat or the place of their actual management is in Liechtenstein; this covers in particular companies with limited liability (Tax Act, Article 44(1)).
Neither in Liechtenstein. A legal person with neither its seat nor its place of actual management in Liechtenstein is taxable only on its domestic income, such as the profit of a permanent establishment there (Article 44(2) and (3)).
Rate. The income tax on legal persons is 12.5% of the taxable net profit (Article 61). A minimum tax of 1 800 francs applies, credited against the income tax; it is not charged to a commercial business whose average balance sheet total over the last three business years did not exceed 500 000 francs (Article 62(1) to (3)).

An Estonian OÜ has its seat in Estonia. If you live in Liechtenstein and the company is in fact managed from there, Liechtenstein can treat it as taxable without limit. Your Liechtenstein tax adviser answers that with the facts of your case.

In Liechtenstein: the owner side

No controlled foreign company rule. The Tax Act as we read it has no rule that adds a foreign company's retained profit to its owner's income.
Dividends to a company. Profit shares from holdings in legal persons do not count towards the taxable net profit of a Liechtenstein legal person (Article 48(1)(e)), but they do when more than 50% of the paying foreign company's total income is lasting passive income — interest, licence fees and similar — not earned in an actual economic activity, and its profit is subject to low taxation (Article 48(3) and (4)). For a holding of at least 25%, low taxation means an effective income tax burden of less than half of the burden in a comparable Liechtenstein case (Article 48(3)(b)).
Dividends to an individual. Profit shares from holdings in legal persons are not subject to the income tax of individuals (Erwerbssteuer), except for business assets where Article 48(3) to (5) applies (Article 15(2)(n)).

An Estonian company pays its corporate income tax only when it distributes profit, so in a year in which it keeps its profit its burden can be low. Whether the passive-income rule reaches a dividend from your company depends on who holds it and on its income; your Liechtenstein tax adviser answers that with your figures.

What the Estonia–Liechtenstein tax treaty says

Resident in both countries. If a person other than an individual is resident in both states, the competent authorities endeavour to determine by mutual agreement of which state it is a resident, having regard to its place of effective management, the place where it is incorporated and any other relevant factors; without such an agreement it is not entitled to any relief or exemption under the treaty except as the authorities agree (convention signed in Rome on 10 July 2025, article 4(3); RT II, 19.11.2025, 2).
Permanent establishment. A permanent establishment is a fixed place of business through which the business of an enterprise is wholly or partly carried on; it includes especially a place of management, a branch and an office (article 5(1) and (2)). The profit attributable to it may be taxed in the state where it is (article 7(1)).
Directors' fees. Fees a Liechtenstein resident receives as a member of the board of directors or a similar organ of an Estonian company may be taxed in Estonia (article 15) — see board member fee or dividend from abroad.
Dividends. Dividends paid by an Estonian company to a Liechtenstein resident may be taxed in Liechtenstein; if Estonia also taxes them at source, the treaty limits that tax to 10 per cent of the gross amount when the beneficial owner is an individual, and 0 per cent in all other cases (article 10(1) and (2)).
From when. The convention entered into force on 26 December 2025 and applies to income from 1 January 2026 (article 30).

So the treaty does not settle a double residence by itself: a company actually managed from Liechtenstein may need an agreement between the two tax administrations before it can rely on the treaty. The multilateral convention on tax treaty measures (MLI) can change the rules of tax treaties; how it applies to your company is a question for your Liechtenstein tax adviser — we do not give that ruling.

What to decide before you form or buy the company

Where the company is actually managed. That is the fact the Liechtenstein Tax Act and the treaty look at.
Who holds it. The passive-income rule for dividends is written for a Liechtenstein legal person as the holder.
Where the work is done. An office or other fixed place of business in Liechtenstein can be a permanent establishment.

What we do on the Estonian side

online formation for an e-resident — €950 Registered address and contact person service for one year are included., or formation by power of attorney — €1,250;
a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included.;
accounting — from €150 / month and the annual report — from €450;
the registered address and contact person after the first 12 months — €350 / year.

Our accounting covers the Estonian company's Estonian obligations. Liechtenstein tax returns and Liechtenstein tax advice are not included. Owners in other countries: Estonian company run from abroad compares the rules side by side.

Prices exclude VAT. All communication takes place by email.

Ready to start? A new Estonian company — online for e-residents or by power of attorney; Liechtenstein tax advice is not included. Order.

Official sources

The laws this article names, by the name of their official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Income Tax Act — Riigi Teataja, English translation

Sources are named in the text, without links. To see which of our services your company needs, open the Business Navigator.

Frequently asked questions

Is my Estonian company taxed in Liechtenstein if I run it from Liechtenstein?

It can be. Liechtenstein taxes a legal person without limit on all its income if its seat or its place of actual management is in Liechtenstein (Tax Act, Article 44(1)). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). Under the Estonia–Liechtenstein tax treaty the competent authorities try to decide such a double residence by agreement, having regard to the place of effective management and of incorporation; without an agreement the company gets no treaty relief (article 4(3)). Liechtenstein has no controlled foreign company rule, but a dividend from a low-taxed foreign company with mostly passive income is not exempt for a Liechtenstein company (Article 48(3)). Ask a Liechtenstein tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from Liechtenstein: what is taxed where