Abstract

The competition between the European legal systems which are familiar with the institution of the private-benefit foundation is played out not only in tax law but also in civil law. In this context, issues regarding foundation governance have increasingly come to the fore in the recent past. When comparing the new Liechtenstein foundation law to the corresponding laws in other jurisdictions, it is striking that there is such a huge range of mechanisms available to achieve an optimal governance structure. In this respect, the legislator has focused particularly on the active role of the beneficiaries as control bodies.

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