Not tax or legal advice. This page sorts public sources, as of 1 Nov 2026. Whether and how any of it applies to you is a question for your tax adviser.
In short
- Since 2022 Spain has levied a solidarity tax on large fortunes (Impuesto Temporal de Solidaridad de las Grandes Fortunas, Ley 38/2022). It applies to net wealth above €3m.
- Originally temporary, it was extended indefinitely at the end of 2023 by Real Decreto-ley 8/2023. It is law in force.
- New in 2026: Orden HAC/652/2026 (BOE 29 Jun 2026) amended form 718. Following Supreme Court rulings from late 2025, a cap now applies to non-residents too.
- Spain has also had an exit tax since 2015 (Art. 95 bis LIRPF): if you were resident for 10 of the last 15 years and hold shares worth more than €4m, unrealised gains are taxed when you leave.
- Liechtenstein doesn't override Spanish rules. Whether the EEA rule with deferral until sale applies to a move to Liechtenstein has to be checked case by case.
Status check 1 Nov 2026
What applies in Spain?
Sorted, with sources. Both taxes are law in force. What is new in 2026 is mainly a change to the form.
ESlaw
Solidarity tax on large fortunes
- Ley 38/2022, since 2022 (BOE, Spanish). It complements the regional wealth tax (Impuesto sobre el Patrimonio); what is paid there is credited.
- Allowance of €700,000 for residents. The first €3m of taxable wealth carries no tax.
- Rates above that: 1.7% up to €5.35m, 2.1% up to €10.7m, 3.5% above.
- Extended indefinitely by Real Decreto-ley 8/2023 (BOE, Spanish).
ESlaw
Exit tax (Art. 95 bis LIRPF)
- Unrealised gains on shares and holdings are taxed on departure (BOE, AEAT, Spanish).
- Conditions: resident for 10 of the last 15 years and shares worth more than €4m, or more than 25% of a company with shares worth more than €1m.
- Moves to an EU or EEA state with effective exchange of tax information: by election, the tax only falls due if you sell within 10 years, leave the EU/EEA or breach reporting duties.
- For temporary moves, for example for work, a deferral is possible on application. If you return within the period without selling, nothing is owed.
ESadjusted
What's new in 2026
- Orden HAC/652/2026 of 26 Jun 2026: new form 718, first for tax year 2025 (Agencia Tributaria, Spanish).
- Background: the Supreme Court ruled on wealth tax on 29 Oct and 3 Nov 2025, and the central tax tribunal TEAC applied this to the solidarity tax on 18 Dec 2025 (Ministry of Finance, Spanish).
- Result: the income-related cap also applies to non-residents.
As of 1 Nov 2026. Law in force. We will update this page when things change.
What it honestly means
Spain often stands for "wealth tax" in headlines. For founders, three things matter:
- Exit taxes hit those who move late. What's taxed is the growth built up in Spain until you leave. If you're seriously considering a move, plan early and get advice in both countries.
- Substance, not a mailbox. An address alone is neither a residence nor a company seat. If you build something in Liechtenstein, you need a real presence: a registered company with its seat and desks on the ground, a team, and decisions made here. More: Substance in Liechtenstein.
- Moving doesn't erase your home country's rules. Spain applies its own rules to decide whether someone has really left and which relief applies. Double taxation questions come on top: Double taxation and Liechtenstein.
Why we still like talking about Liechtenstein: the environment is predictable. Founders plan in years, not in headline cycles.
Exit taxes in Europe compared
Almost everywhere, what grew in the old country is taxed. A short comparison as of 1 Nov 2026. Every country including wealth and data taxes: Tax news Europe.
| Country | Status 1 Nov 2026 | Source |
|---|---|---|
| Italy | Government bill, not law. 26% on unrealised gains from €800,000 in financial assets, resident 6 of 10 years, planned from 1 Jan 2027. | Il Sole 24 Ore |
| Germany | Law in force. From a 1% stake in a corporation and 7 of 12 years fully taxable: the gain in the shares is taxed on moving away. Instalments over seven years on application. | § 6 AStG (German) |
| France | Law in force, change at first reading. From €800,000 in securities, resident 6 of 10 years. Today the tax lapses after 2 or 5 years; on 30 Oct 2026 the Assemblée nationale adopted 15 years at first reading. | Amendment I-462 (French) |
| Norway | Law in force. Moves since 20 Mar 2024: unrealised gains above NOK 3m, payable within 12 years. | Skatteetaten |
| Belgium | Law in force since 2026. Exit tax as part of the 10% capital gains tax. Automatic deferral for EU and EEA states among others; not owed without a sale within 2 years. For Liechtenstein, check case by case. | SPF Finances (French) |
| Netherlands | Law in force for box 2. Leaving with a stake of 5% or more triggers a protective assessment (conserverende aanslag). Box 3 is being rebuilt; that is still in parliament. | Belastingdienst (Dutch) |
| Spain | Law in force. From €4m in shares and holdings, or more than 25% of a company worth more than €1m, resident 10 of 15 years. For moves to an EU or EEA state with exchange of information, by election only due on a sale within 10 years. For Liechtenstein, check case by case. | Art. 95 bis LIRPF (Spanish) |
| Austria | Law in force. Moving away counts as a disposal of capital assets, special rate 27.5%. For moves to an EU/EEA state, on application assessed only on an actual sale. For Liechtenstein, check case by case. | § 27(6) EStG (German) |
| Denmark | Law in force. From DKK 100,000 in shares and usually after 7 years of tax liability, gains count as realised on departure. Interest-free deferral; security required outside the EU and the Nordic countries. For Liechtenstein, check case by case. | Skattestyrelsen (Danish) |
| United Kingdom | No general exit tax. If you return within 5 years, gains made while abroad can be taxed (temporary non-residence). | gov.uk HS278 |
| Ireland | No general exit tax. Return rule for domiciled individuals after no more than 5 years away (holdings of 5% or more, or over €500,000). | Revenue s. 29A |
| Switzerland | No general exit tax for individuals. According to the Federal Department of Finance, the Federal Council considers one ruled out under the constitution. | Federal Department of Finance (German) |
The basics: Exit tax.
Liechtenstein in numbers
| Item | Status | Source |
|---|---|---|
| Corporate income tax | 12.5%, since 2011 (Tax Act in force since 1 Jan 2011) | llv.li, gesetze.li SteG |
| Minimum corporate income tax | CHF 1,800 a year | llv.li |
| EEA | Member since 1995 | gesetze.li |
| Currency | Swiss franc (CHF) | – |
| Blockchain Act (TVTG) | in force since 2020 | gesetze.li |
| GmbH (LLC) | from CHF 10,000 share capital | GmbH fact sheet, llv.li |
| EU list of non-cooperative tax jurisdictions | Liechtenstein is not on it (update 9 Oct 2026) | Council of the EU |
It's not a hack. It's boringly predictable, and that's the point. How incorporation works: GmbH formation in Liechtenstein.
digihub · In der Specki 3, Schaan
Substance means a real place to work
If you're looking at Liechtenstein seriously, you need more than an address: an office, people on the ground, decisions made here. At digihub in Schaan you get real desks, not a mailbox: coworking with a Flex Desk from CHF 169, a Full Desk from CHF 299 or a Private Office from CHF 549 a month, plus meeting room and community. A business address is available by agreement (Registered office & business address).
Come by for a coffee, and we'll see together whether Liechtenstein even makes sense for you.
Read next
- Tax news Europe: all countries at a glance
- Italy exit tax: what the draft says
- France exit tax: 15 years at first reading
- Norway exit tax: the 12-year rule
- Belgium: 10% capital gains tax and exit tax
- Netherlands: box 3 in parliament
- UK: Founders' Relief and non-dom
- Switzerland: JUSO initiative rejected, what applies now
- Austria: inheritance tax called for, exit tax applies
- Denmark: no wealth tax, inheritance duty proposed
- Ireland: 31% capital gains tax in Budget 2027
- Exit tax: the basics
- What does substance mean in Liechtenstein?
- GmbH formation in Liechtenstein
Sources
- BOE: Ley 38/2022, solidarity tax (Spanish)
- BOE: Real Decreto-ley 8/2023 (Spanish)
- Agencia Tributaria: change to form 718 (29 Jun 2026, Spanish)
- Agencia Tributaria: solidarity tax on large fortunes (Spanish)
- Ministry of Finance: Orden HAC/652/2026 with explanatory notes (Spanish)
- BOE: Ley 35/2006 (IRPF), Art. 95 bis (Spanish)
- Agencia Tributaria: special rule on change of residence (Spanish)
- llv.li: corporate income tax (German)
- Council of the EU: EU list of non-cooperative jurisdictions, update 9 Oct 2026
- llv.li: GmbH fact sheet (German)
Not tax or legal advice. Orientation based on public sources, as of 1 Nov 2026. Legislation can change quickly. Please check your own case with a tax adviser or lawyer in Spain and Liechtenstein.
Content from digihub.li · reviewed 1 November 2026.