Service

Tax Strategy & Structure

Strategic structuring for internationally active asset holders. Tax advice is rendered exclusively by our partner firm, a tax advisory firm licensed in Germany (§ 3 StBerG).

Structures with
tax-relevant effect

International wealth structuring is not a grey area. It is the intelligent use of existing legal frameworks to structure assets efficiently. The difference lies in expertise: those who know the rules can use them to their advantage.

Tax advice within the meaning of § 2 StBerG is rendered exclusively by our partner firmy firm, licensed in Germany (§ 3 StBerG). Together we develop structures that are legally sound and sustainable in the long term, tailored to the individual circumstances of our clients.

100% Legal

Every structure is based on applicable law. No grey areas, no risks. Full compliance.

International perspective

Tax-relevant structuring does not stop at national borders. We think in jurisdictions, not in forms.

Individually structured

No off-the-shelf solutions. Every structure is tailored to your personal asset and family situation.

Does this sound relevant to your situation? Schedule a complimentary consultation

Instruments

How we optimise
taxes

01

Liechtenstein Family Foundation

  • 0% inheritance tax on asset transfers
  • 0% substitute inheritance tax (advantage vs. German foundation)
  • Corporate tax of only 12.5% on income
  • No gift tax upon contribution
  • Minimum tax of only CHF 1,800/year
02

International Structural Planning

  • Optimal jurisdiction for your assets
  • Coordination between country of residence and structural location
  • Strategic use of double taxation agreements
  • Holding and participation structures
  • Ensuring substance requirements
03

Succession Planning

  • Tax-efficient asset transfer to the next generation
  • Gift vs, inheritance: choosing the right timing
  • Managing forced heirship claims through foundation structures
  • Multi-generational tax planning
  • Family governance and foundation charter
Expertise

Tax advisory with substance

Ronny Walch combines deep tax expertise with a strategic eye for international structures. He does not think in tax returns but in long-term architectures that structure wealth efficiently and legally across generations.

Frequently Asked Questions

What clients want to know

The information below is for general orientation only and does not constitute tax or legal advice. Individual tax advice is rendered exclusively by our partner firm pursuant to § 3 StBerG.

Yes. Tax optimisation is the utilisation of existing legal frameworks for the efficient structuring of assets. Unlike tax evasion, all structures are fully disclosed, all reporting obligations are met, and all applicable tax laws are observed. Liechtenstein participates in the Automatic Exchange of Information (AEOI) and fulfils the key OECD transparency standards.
Yes. German tax residents are obliged to notify the tax authorities of the establishment of a foreign foundation and their status as founder or beneficiary. This reporting obligation arises in particular from § 138 Abs. 2 of the German Fiscal Code (AO). In addition, the German Foreign Tax Act (AStG) contains provisions on tax attribution. We ensure that all reporting obligations are met from the very beginning.
A family foundation in Liechtenstein is subject to a corporate income tax of 12.5% in principle. If the foundation qualifies as a Private Asset Structure (PVS), income from asset management is exempt from corporate income tax. In that case, only the minimum tax of CHF 1,800 per year applies. Liechtenstein levies no inheritance tax, no gift tax, and no substitute inheritance tax. The tax implications in the country of residence of the beneficiaries must be considered separately.
Attribution taxation under § 15 of the German Foreign Tax Act (AStG) means that assets and income of a foreign foundation may be attributed to the founder, or after the founder's death to the beneficiaries, for tax purposes in Germany. Careful structural planning takes this provision into account from the outset, ensuring that the structure remains tax-efficient and compliant.
Liechtenstein has participated in the Common Reporting Standard (CRS) since 2017. This means that account data and asset information are automatically transmitted to the country of tax residence. Transparency is the foundation of every reputable wealth structure.
Next Step

Position your structure
strategically

In a confidential initial conversation we place your current structure strategically and identify possible courses of action. Subsequent tax advice is rendered by our partner firm (§ 3 StBerG).

Schedule a consultation

30 minutes. No obligation. Discreet.