Private foundations: jurisdictions compared
A foundation is a legal entity without shareholders that manages family wealth under its charter. We compare eight jurisdictions on capital, council and tax and set up the foundation with licensed local partners.
A private foundation is for a family that wants to hold its wealth in one structure and decide in advance who will manage it and who receives distributions after the founder dies. A foundation is a legal entity without shareholders: the founder transfers assets to it, the foundation council manages them under the charter and internal regulations, and the beneficiaries do not become owners. This is what sets a foundation apart from a trust, where the assets are held by a trustee: a detailed comparison is in our article trust or foundation: which to choose.
We work with foundations in eight jurisdictions. They differ in minimum capital, council requirements and tax, so the choice starts with the budget and with where the family lives and the assets sit.
Jurisdictions compared
| Jurisdiction | Minimum capital | Council and oversight | What to know |
|---|---|---|---|
| Seychelles | $1 | one or more council members, registered agent | government fees $200 on registration and $200 a year; business tax and income tax laws do not apply |
| Panama | $10,000 | at least 3 individuals or one legal entity, resident agent | $400 annual fee; foreign assets and income from them are not taxed |
| Liechtenstein | 30,000 francs, euros or dollars | foundation council; a formation notice is filed with the Office of Justice within 30 days | minimum tax of 1,800 francs a year; private asset structure status exempts from tax beyond that minimum |
| Austria | €70,000 | board of at least 3, two of them living in the EU or EEA | 3.5% tax on contributions to the foundation from 1 January 2026 |
| Jersey | none set | the council must include a licensed qualified member; a guardian is mandatory | set up and supervised through the Jersey Financial Services Commission |
| Guernsey | none set | registration is filed only by a licensed fiduciary | a guardian is needed if the foundation has a purpose without beneficiaries |
We also set up foundations in Malta and Gibraltar and work with Swiss foundations. Conditions for each country are on its page.
We will calculate online the cost of setting up the structure and running it for a year.
How to choose a jurisdiction
- Modest capital and a simple task, such as holding a company stake and passing it to the children: usually the Seychelles. The capital is nominal, one council member is enough and government fees do not exceed $200 a year. The comparison with Panama is on the offshore private foundations page.
- Large capital and European banks: Liechtenstein or Austria. The thresholds are higher, but court practice is settled and the reputation is accepted by European banks and family offices.
- British legal tradition: Jersey and Guernsey. The council works with a local licensed company, and the guardian makes sure the council follows the charter.
- The family lives in the EU: we look at how the foundation will be taxed in the country of residence. An Austrian foundation pays tax on contributions, and other countries may apply controlled foreign company rules.
How we set up a foundation
- Understanding the task. Which assets go in, who the founder and beneficiaries are, where they live and pay tax, and whether an account is needed.
- Choosing the country and the council. Austria needs a board of 3 with two EU or EEA residents, Jersey a licensed council member, and in Guernsey registration is filed by a licensed company. We find licensed local partners.
- Charter and regulations. The charter holds the basic provisions, the regulations name the beneficiaries and set the distribution rules. We draft them so the founder keeps the influence needed while the foundation stays independent.
- Registration and capital. We pay in the minimum capital: in Liechtenstein it must be fully paid in at formation, and a private foundation files a notice with the Office of Justice within 30 days. In Austria the capital is at least €70,000.
- Account, asset transfer and maintenance. We open the account, transfer shares and property, and keep council minutes and annual reporting.
Why foundations get refused
- Source of funds not proven. The bank and the local agent check where the capital comes from before registration, and without documents the process stops.
- Council not in place. In Austria two of the three board members must live in the EU or EEA; in Jersey a foundation cannot be set up without a licensed council member.
- Not enough capital. European thresholds are high: 30,000 francs in Liechtenstein and €70,000 in Austria.
- A foundation set up against creditors. A transfer to a foundation on the eve of a lawsuit can be challenged, so the structure is built well in advance.
What we do
We compare jurisdictions for your capital and family, draft the charter and regulations, find licensed partners for the council, register the foundation, open the account and run the foundation afterwards. Before registration we check the tax position in your country of residence and, if needed, prepare controlled foreign company filings. Our prices for the Seychelles, Austria and Liechtenstein are in the table below; for other countries we quote after a short consultation and fix the quote in writing.
Fees
| Service | Price |
|---|---|
| Seychelles private foundation registration | from $2 390 |
| Austrian private foundation (Privatstiftung) setup | €30 000 |
| Liechtenstein foundation (Stiftung) / Trust reg. registration | 90 600 CHF |
The country for a foundation is chosen by the size of capital and the family's goal
Foundations differ by country in minimum capital, council requirements and taxes: what makes sense for a large family fortune will eat a small one in costs. The usual mistakes: choosing a country without working out the taxes of the founder and beneficiaries, leaving the founder so much control that the foundation stops protecting assets, not deciding who will manage it after the founder's death. We compare countries for your goal, prepare the charter and rules, register the foundation and open the account.
Registering a private foundation ranges from $2,390 in the Seychelles to about $110,000 in Liechtenstein; a manager will calculate the total for your goal in the chat.
FAQ
Where to set up a private foundation in Europe?
How much capital and what taxes for an Austrian foundation?
What tax does a Liechtenstein foundation pay?
How does a Jersey foundation differ from a Guernsey one?
Which foundation suits modest capital?
Can the founder control the foundation?
Need a private foundation for family wealth?
We review your goals, compare a foundation with a trust and choose the country, then prepare the charter and documents. The catalogue covers trusts and foundations worldwide.
The Murblz consultant replies straight away in the chat on this page. Describe your situation and we will work it out together.
Free consultation