Liechtenstein: the neighbour as a gateway

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Liechtenstein adopted its Token and Trustworthy Technology Service Provider Act in October 2019 and brought it into force on 1 January 2020. The Act took a different approach from the Swiss DLT Act by introducing the concept of the token as a container of rights, which can represent any right, and by regulating its transfer in general terms. It also created a register of service providers for the token economy, such as token issuers, custodians and exchanges, which were subject to registration with the Financial Market Authority.¹ The Act attracted a number of crypto companies to Vaduz, among them some from Zug.

With the application of MiCA in the European Economic Area, Liechtenstein adapted its law. The registration regime of the Act was replaced for most services by the European authorisation regime, while the civil law provisions remain in force.² Liechtenstein providers authorised under MiCA can serve the whole European market. For Zug companies, a Liechtenstein subsidiary offers access to that market with a short distance from Zug, a legal culture close to that of Switzerland and the Swiss franc as currency. The author's experience as the former owner of a Liechtenstein trust company, which went through the owner-control procedure there, confirms that the Liechtenstein authorities apply their regulation with thoroughness. The applicant should therefore plan for a careful review of its owners and its organisation.

Notes

Gesetz vom 3. Oktober 2019 über Token und VT-Dienstleister (Token- und VT-Dienstleister-Gesetz; TVTG), LGBl. 2019 Nr. 301, LR 950.6, in force 1 January 2020, gesetze.li: Art. 2 (token as carrier of rights), Art. 12 ff. (registration of VT service providers with the FMA). ↩
Liechtenstein Financial Market Authority (FMA), "MiCAR", fma-li.li: EWR-MiCA-DG in force since 1 February 2025; transitional period for TVTG-registered providers until 1 July 2026; the civil law provisions of the TVTG remain in force and apply alongside MiCAR in mutually exclusive areas. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.

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Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

My approach is to act as a trusted advisor who works directly with decision-makers, on an equal footing: I start from what you want to achieve and shape every structure, contract and tax decision around your commercial goals and how it improves your after-tax return. As “lawyers who make it happen”, my team and I stay involved until your company is set up, your structure is in place and your transaction has closed, and we remain available for any follow-on work that may be required. You benefit from bespoke solutions and personal attention, and sound, friendly and practical advice. We are not the lowest-cost provider in the market, nor do we intend to be; our aim is to deliver well-founded, proper solutions and excellent value for money.

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Liechtenstein: the neighbour as a gateway

Notes

Setting up or expanding in Switzerland?