Launch and Scale in Luxembourg, Liechtenstein and Switzerland with Clear Rules and Stable Regulation

Luxembourg is an established EU centre for investment funds, holding companies, fintech businesses and regulated crypto-asset services. The CSSF authorises Crypto-Asset Service Providers under MiCA, allowing authorised services to be passported across the European Union.

Luxembourg is commonly considered for RAIF, SIF, SICAV and SCSp fund structures, tokenised investment products, payment and e-money businesses and international holding structures. The appropriate vehicle depends on the investment strategy, target investors, regulatory status and required local substance.

A standard company established in Luxembourg City with taxable income above €200,000 is generally subject to a combined corporate tax rate of approximately 23.87%. Eligible Luxembourg companies may also benefit from EU rules governing intra-group dividends, interest and royalties, as well as Luxembourg’s extensive tax treaty network, subject to applicable eligibility, substance and anti-abuse requirements. The jurisdiction is supported by a well-established fund administration, banking and professional services ecosystem.

Liechtenstein is a member of the European Economic Area and applies MiCAR through its national implementation legislation. CASPs are authorised by the Financial Market Authority Liechtenstein and may passport their approved crypto-asset services across the EEA.

The national Token and Trusted Technology Service Provider Act continues to apply to certain activities outside the scope of MiCAR. Its technology-neutral framework may be relevant for tokenisation projects, digital ownership structures and services involving tokens not regulated under MiCAR.

Liechtenstein applies a flat 12.5% corporate income tax on taxable net profits, subject to a minimum annual corporate tax of CHF 1,800. Dividends and capital gains from qualifying shareholdings may be excluded from taxable income, although anti-abuse and low-tax rules must be considered. The standard VAT rate is 8.1%, and Liechtenstein and Switzerland form a common VAT territory.

Liechtenstein may also be suitable for foundations, family-office structures and international businesses seeking an EEA base with established corporate and wealth-planning vehicles.

Switzerland is outside the EU and EEA and operates its own regulatory framework for fintech, blockchain and digital assets. Depending on the business model, FINMA licensing, AML supervision or other financial-market requirements may apply.

Swiss law recognises ledger-based securities and provides a licensing framework for DLT trading facilities. Switzerland is frequently considered for technology operating companies, protocol foundations, non-profit associations, token issuers and blockchain infrastructure projects.

A Swiss structure does not provide MiCA passporting rights, so the location of clients, target markets and cross-border activities should be reviewed before implementation.

The right jurisdiction depends on more than tax rates or market reputation. We compare:

(a) the proposed products, services and token model;

(b) the location of founders, employees, clients and investors;

(c) licensing and regulatory requirements;

(d) fundraising and investor expectations;

(e) tax residence and economic substance;

(f) capital, governance and local-presence requirements;

(g) banking and payment-account access; and

(h) formation costs and ongoing compliance obligations.

This helps create a corporate structure that is practical for day-to-day operations and understandable to investors, banks and regulators.