US Company Formation from Liechtenstein (2026): US Subsidiaries of Liechtenstein Manufacturers, Foundations and AGs Owning US Companies, 12.5% Tax at Home, No US Treaty, and the US LLC vs C-Corp Choice

Liechtenstein is small, but its companies are global. Its manufacturers sell tools, dental products, precision components and building technology around the world, and several run large US operations. Its fiduciary industry administers companies, foundations and trusts for owners in many countries. And its residents, many of them entrepreneurs and professionals, invest and do business in the USA.

Setting up a US company from Liechtenstein raises questions that most countries' residents never face:

• there is no US–Liechtenstein income tax treaty, so US withholding taxes apply in full;
• many US companies are owned not by individuals but by a Liechtenstein AG, Anstalt or foundation, and how the US classifies that owner changes the US tax result;
• Liechtenstein's 12.5% corporate tax and its participation exemption interact with US tax in specific ways.

This guide covers each, then compares US LLC formation with US C-Corp formation. Everything can be done without visiting the USA.

In short: A Liechtenstein resident, company or foundation can form a US LLC or C-Corporation without visiting, get an EIN without an SSN or ITIN, and apply for a US business bank account remotely. With no income tax treaty, US dividends, royalties and related-party interest paid to Liechtenstein are withheld at 30%. A US LLC owned by a Liechtenstein company is often better treated as a corporation for US tax. A foundation or Anstalt owning a US company needs a US classification analysis. A US subsidiary of a Liechtenstein manufacturer is usually a Delaware C-Corporation.

Liechtenstein's tax position

• Corporate income tax: a flat 12.5% on net profit, with a minimum tax of CHF 1,800 a year, credited against the profit tax.
• Participation exemption: dividends and gains on shares are generally exempt, subject to anti-abuse rules for low-taxed passive income.
• Private asset structures (PVS): qualifying foundations and companies that only manage private assets pay just the minimum tax.
• Personal income tax: progressive, combining state and municipal tax, with a top rate around 22% depending on the municipality.
• Wealth: instead of a separate wealth tax, a notional return on net assets (set at 4%) is added to taxable income. Your US company's value counts.

Liechtenstein is part of the EEA and uses the Swiss franc in a customs union with Switzerland. It has a FATCA agreement with the USA and takes part in automatic exchange of account information.

No US–Liechtenstein income tax treaty

Liechtenstein has a tax information exchange agreement with the USA, but no income tax treaty. So:

• 30% US withholding on dividends from a US corporation to a Liechtenstein owner;
• 30% on US-source royalties;
• 30% on related-party interest.

Dividends that reach a Liechtenstein AG are usually exempt in Liechtenstein, but the 30% US withholding is still lost. That shapes how profits should move out of a US company: through arm's-length service fees or purchase prices for goods, where commercially justified, rather than dividends.

US LLC formation from Liechtenstein

Owned by an individual

The IRS disregards a single-member LLC owned by a non-resident individual. If you run the business from Liechtenstein, and the LLC has no US office, staff or dependent agents, its income is generally not taxed in the USA (see effectively connected income explained). The LLC files Form 5472 with a pro forma Form 1120 every year, with a $25,000 penalty for missing it (see Form 5472 explained).

In Liechtenstein, the LLC's profit is generally taxed as your own business income, and its value enters the notional wealth return.

Example: a Vaduz consultant

These figures are illustrative.

Andrea, an engineer in Vaduz, advises US building-technology companies on European standards. A Wyoming LLC with a US business account invoices US clients and gives them a Form W-9. All work is done from Liechtenstein. Annual revenue is US$180,000.

• USA: no US income tax; Form 5472 and a pro forma 1120.
• Liechtenstein: the profit is Andrea's self-employment income, taxed at progressive rates, with the notional return on the LLC's net assets added.

Owned by a Liechtenstein company

A single-member LLC owned by a Liechtenstein AG is, by default, disregarded, which makes the AG itself the taxpayer for anything the LLC does in the USA. If the LLC has US business income, the AG must file a US return (Form 1120-F) and may face the branch profits tax. For that reason, a Liechtenstein company often elects for its US LLC to be taxed as a corporation, which gives the same result as a C-Corporation while keeping the LLC's flexibility. See LLC vs Inc.

Owned by a foundation or Anstalt

How the USA classifies a Liechtenstein foundation (Stiftung) or establishment (Anstalt) depends on its terms and purpose. A foundation may be treated as a trust or as a corporation; an Anstalt is usually treated as a corporation unless it elects otherwise. The classification decides who the US treats as owner, which forms are filed, and whether US estate tax can apply. Get US tax advice before a foundation acquires a US company or US property.

US C-Corp formation from Liechtenstein

US tax position

A US corporation pays 21% federal tax plus state tax, files Form 1120 and Form 5472, and its dividends to Liechtenstein are withheld at 30% (see the 21% corporate tax explained).

Example: a manufacturer's US subsidiary

Take an illustrative case: a Schaan precision-components maker with US customers in medical devices and aerospace forms a Delaware corporation as its US subsidiary, with a sales and service office in Ohio and a small warehouse.

• The US corporation buys products from the parent and resells them, employs sales and service staff, and pays 21% plus state tax on its profit.
• Transfer pricing: the parent sells at arm's-length prices, documented, so the US subsidiary earns a routine distributor margin and most of the manufacturing profit stays in Liechtenstein at 12.5%.
• Imports: the subsidiary is importer of record. Tariff rates on European and Swiss-area goods have changed repeatedly since 2025; the company checks current rates with its customs broker. See importer of record for a foreign-owned US company.
• Aerospace and defence customers may bring export control rules on technical data shared between the two companies.
• Dividends to the parent lose 30%, so the subsidiary reinvests its profits in US growth.

See US subsidiary for a foreign company.

Other cases

• Start-ups raising US money, which need a Delaware C-Corporation (see raising investment as a foreign founder).
• US real estate, where the choice between personal, LLC, corporate and foundation ownership turns on income tax and US estate tax. See real estate investment LLC for foreigners and US estate tax on US company shares.

Beneficial ownership

Since March 2025, companies formed in the USA no longer file beneficial ownership reports with FinCEN. But US banks still identify the people who ultimately own and control the company. Where a foundation or trustee sits in the chain, expect to provide the foundation documents, the founder, beneficiaries or protectors as the bank requires, and the Liechtenstein trustee's details.

Which state

• Wyoming for an individual's or holding LLC.
• Delaware for a subsidiary or start-up.
• The state where US staff or a warehouse will be.

See best state for non-residents.

What it costs

UCB's prices include state fees and the first year of registered agent service:

• Wyoming LLC with EIN: $249, or $348 with a US bank account application.
• Delaware corporation with EIN: $358.

A Wyoming LLC costs $121 a year to keep active, or $421 with the annual federal return. See what a US LLC costs every year.

Documents

• Passport of each owner or controller.
• Proof of address: an LKW electricity bill, a telecom bill or a bank statement.
• For a company owner: a commercial register extract, articles and a board resolution.
• For a foundation owner: the foundation deed and by-laws as the bank requires, and the members of the foundation council.

See US business bank accounts for non-residents.

Mistakes to avoid

• Paying dividends from a US corporation without planning for the 30% withholding.
• Leaving a company-owned LLC disregarded when it has US business income.
• Moving US assets into a foundation without US classification advice.
• Weak transfer pricing between a manufacturer and its US subsidiary.
• Forgetting Form 5472 because the LLC owes no US tax.

Frequently asked questions

Can a Liechtenstein resident form a US company without visiting? Yes. Formation, the EIN and the bank application are all remote.

Do I need an SSN or ITIN? No. The EIN is issued on Form SS-4 without either.

Is there a US–Liechtenstein tax treaty? No income tax treaty. US withholding applies at 30%.

Can a Liechtenstein foundation own a US LLC? Yes, but how the US classifies the foundation affects the US tax result. Get US advice first.

Does a US LLC owned by me personally pay US tax? Not if it has no US office, staff or agents. It files Form 5472 and a pro forma 1120 every year.

How UCB can help

We form US companies for Liechtenstein owners, companies and foundations remotely: the state filing, EIN, registered agent, US business address and bank application, through our formation, EIN and bank account package. Each year we file Form 5472, Form 1120 or the other federal returns through our US tax filing service. We do not advise on foundation structuring, transfer pricing or Liechtenstein tax. See the Switzerland guide and Germany guide for related rules.

Setting up a US company from Liechtenstein? WhatsApp us at +1 315 961 2956 or email enquiries@ucbsolutions.com.