A private foundation is an independent legal entity used to preserve wealth. The founder transfers assets to it permanently; asset management is governed by the charter and continues after the founder's death. For families from civil-law countries, a foundation is often more convenient than a trust: civil law is accustomed to working with legal entities, while fiduciary relationships are foreign to it.
Private foundations are used for asset ownership, protection and succession. For investment funds (LP/GP, Cayman, RAIF, VCC) see Private investment funds.
History and Origins
The modern private foundation grew out of the European tradition of institutions, but as an instrument for private capital it took shape in Liechtenstein. The Persons and Companies Act (PGR) of 20 January 1926 gave families in continental Europe for the first time a structure that performed the functions of an Anglo-Saxon trust, but in the form of a legal entity. This model—the Stiftung—became the benchmark for decades.
Later, other jurisdictions adopted the idea. Panama enacted Law No. 25 of 12 June 1995 on the private interest foundation, making foundations mass-market and affordable. Austria introduced the Privatstiftung in 1993 to retain family businesses. In 2009–2013, foundations also appeared in common-law offshore centres—in Jersey (Foundations (Jersey) Law 2009, in force from 17 July 2009) and Guernsey (registry opened in January 2013), where they coexist with trusts.
Legal structure of a foundation
A private foundation (foundation, German: Stiftung) is a legal entity without members or shareholders: the founder transfers assets to the foundation, which manages them in the interests of beneficiaries according to the charter. Unlike a trust (which is a relationship, not an entity), a foundation is a separate legal person, a form more familiar to civil-law countries.
The internal structure of a foundation is built on several roles. The founder endows the foundation with property and sets its purpose. The foundation council (Stiftungsrat) manages the assets and is responsible for implementing the charter. Beneficiaries receive distributions—either according to clear rules or at the council's discretion (discretionary). Often a protector is appointed, who supervises the council and approves key decisions. Detailed distribution rules are set out in a separate confidential document—by-laws (German: Beistatut)—which does not appear in the public register. The foundation holds the holding company, accounts or PTC shares and makes distributions to beneficiaries.
Foundation and trust: differences
A trust is an Anglo-Saxon construct: the settlor transfers assets to a trustee, who holds legal title for beneficiaries. A foundation is a "company without owners" with its own legal personality, council and charter. The two structures are compared on ten criteria using the US trust, the form most often considered alongside a foundation by families with American members, US-situs assets or an existing trustee in Delaware or South Dakota.
| Criterion | Private foundation | US trust |
|---|---|---|
| Legal personality | Separate legal person; owns the assets itself (DIFC Law 3/2018, Art. 10: property is not held on trust) | A relationship, not an entity; the trustee holds legal title |
| Constitutive documents | Charter or statutes (filed or deposited) plus private by-laws or regulations | Trust instrument, private; no registration anywhere |
| Founder or settlor control | Reserved powers in the charter; founder may sit on the council (ADGM, DIFC); excess control leads to look-through | Revocable grantor trust: full control, no protection; irrevocable: powers through a protector or trust protector |
| Creditor protection and look-back | Liechtenstein 1 year (gratuitous) or 5 years (intent), Art. 65, 67, 74 RSO; Seychelles 2 years; Panama 3 years (Art. 15); ADGM s. 30 requires an insolvency or fraud finding | Self-settled DAPT in 20 states: 2 years in Nevada, South Dakota, Wyoming, 4 years in Delaware and Alaska; 10-year federal bankruptcy look-back under 11 U.S.C. § 548(e) |
| Forced heirship | Statutory firewall in Jersey (Art. 32), Guernsey (s. 37), ADGM (s. 29), DIFC (Arts. 14–16), Panama (Art. 14, Panamanian forum only); none in Liechtenstein or Austria | No forced heirship in US law beyond the spousal elective share; foreign heirs litigate in their own forum |
| Recognition abroad | A legal person that civil-law courts and banks read without translation | Hague Trusts Convention 1985 signed by the US but not ratified; civil-law recognition uneven |
| Tax at entity level | Liechtenstein 12.5% or PVS minimum tax; Jersey and Guernsey 0%; UAE 9% or fiscal transparency on application (MD 261/2024); Panama territorial | Grantor trust transparent; non-grantor trust is taxed at 37% above USD 16,000 of taxable income in 2026; foreign grantor rules and Form 3520 for non-US settlors |
| Register and publicity | Charter often public (Jersey, DIFC, Austrian Firmenbuch); beneficiaries in private by-laws; UBO registers closed to the public since CJEU C-37/20 | No register; the Corporate Transparency Act does not reach a common-law trust, and FinCEN exempted domestic entities in March 2025 |
| Duration | Perpetual in Liechtenstein, Panama, Jersey, the UAE; Malta caps a private foundation's term by statute | Rule against perpetuities by state: South Dakota unlimited, Wyoming 1,000 years, Nevada 365 years |
| Public cost | Registrar tariffs USD 200–1,000 to set up and USD 200–650 a year; Liechtenstein minimum tax CHF 1,800 a year | No registry fee; trustee remuneration is market-set |
Civil-law families tend to choose a foundation, while common-law families tend to choose a trust. A foundation answers the question "who owns this" with its own name, which is what a French notary, a German tax office under § 15 AStG or a Swiss bank compliance officer wants to see; a trust answers with a split between legal and beneficial title that must first be characterised through the Hague Convention or their own case law. The price of the foundation's form is publicity: a charter is held in a register in Jersey, the DIFC or the Austrian Firmenbuch, while a US trust instrument remains a private document held by the lawyer.
On creditor protection the two types of structure have different challenge periods. The US domestic asset protection trust works on a state statute that only twenty states have, that other states' courts have declined to honour for their own residents, and that federal bankruptcy law overrides with a ten-year look-back for self-settled trusts; the foundation firewalls of Jersey, Guernsey, ADGM and the DIFC are tested in the foundation's own court and bind that court alone. Neither shields against a claim that had already matured when the assets went in, which is why either structure is established in advance, allowing the look-back periods to expire.
A foundation pays a low tax in its home jurisdiction, but the founder's and beneficiaries' countries tax the foundation's income or its distributions under their own attribution and CFC rules; a US non-grantor trust reaches the top federal bracket at USD 16,000 of retained income, so US-connected families distribute income annually or keep grantor status. Where one family has members on both sides, the usual answer is a foundation at the top holding a private trust company that acts as trustee of the US-side trusts, which is the construction in PTC.
Jurisdictions
The benchmark is Liechtenstein (Stiftung with a century of practice). Panama offers the private interest foundation more cheaply. Jersey and Guernsey combine foundations and trusts in one legal system. The choice depends on the goal: succession, asset protection, charity — up to a private museum with an FMV deduction — or retention of a family business.
Liechtenstein (Art. 552 PGR) provides a century of case law and bank confidence; Panama, low cost and the territorial principle, under which foreign income is not taxed; Jersey and Guernsey, common law with a statutory firewall and a regulated fiduciary on the council; ADGM, the DIFC and RAK ICC, a UAE forum for Gulf-resident families. All thirteen regimes are compared by key criteria in the matrix section of this page, with a profile table and a five-year cost example. For protection against a hostile creditor, families more often take Nevis and Cook Islands trusts (asset protection trusts) and choose a foundation where succession and business ownership are paramount.
What They Are Used For
The main task of a foundation is succession. It allows the transfer of a family business or portfolio to the next generation without fragmenting control among heirs, while mitigating the effects of forced heirship—the mandatory share that civil law reserves for close relatives. Through the charter, the founder sets who receives distributions and under what conditions: for education, for medical care, after a certain age.
The second common task is ownership of structures. A foundation is placed at the top of a holding: it holds shares of operating companies or acts as a shareholder of a private trust company, which manages family trusts. In combination with a family office, a foundation provides capital management that does not depend on the life and capacity of one person. It serves as the basis of a long-term family structure.
Management and Bodies
The foundation council is its governing body. In Liechtenstein it is the Stiftungsrat, in Panama the Foundation Council (requirements for its composition are covered in the jurisdiction-specific articles). The council is obliged to act in the interests of the beneficiaries and within the statutory purpose. The founder has the right to retain certain powers—to appoint and remove council members, to change the circle of beneficiaries—but excess control is dangerous: if a court or tax authority decides that the founder manages the assets as his own, the foundation may be deemed a sham and look-through applied. Therefore, the allocation of powers is planned in advance and recorded in corporate documents.
Taxes, Transparency, and Regulation
The foundation's own tax burden is usually low. A Liechtenstein family foundation not conducting economic activity qualifies for the preferential Private Asset Structure (PVS) regime with a minimal annual tax, while a Panamanian foundation is not taxed on foreign income by virtue of the territorial principle—rates and conditions are covered in the jurisdiction-specific articles. But the taxes of the founder and beneficiaries in their countries of residence do not disappear: CFC rules and income attribution norms can tax the foundation's income at the level of a specific individual.
Transparency has increased dramatically in recent years. A foundation almost always falls under CRS—as a Financial Institution or as a Passive NFE, and then data on the founder, council, and beneficiaries goes to the tax authorities of their countries. Beneficial ownership registers work in parallel. Public access to these registers was restricted: on 22 November 2022, the EU Court of Justice in joined cases C-37/20 and C-601/20 invalidated the provision of the directive that opened UBO registers to the general public, citing Articles 7 and 8 of the EU Charter. Access remained with tax and law enforcement authorities; the general public lost it (details in the material on beneficial ownership registers).
Risks and Common Mistakes
The first risk is excessive founder control, leading to look-through. The second is conflict with forced heirship: heirs with a mandatory share can challenge the transfer of assets to a foundation, especially one made shortly before death. The third is recognition of the foundation abroad: countries unfamiliar with such a structure sometimes interpret it as a trust, corporation, or transparent structure, and tax consequences change. Finally, banks scrutinize a foundation more strictly than an ordinary company—they need a clear purpose, source of funds, and understandable circle of beneficiaries.
Development of private foundations
The institution is developing in two directions. The first is transparency: following CRS, CARF — an exchange of data on crypto assets — is forthcoming, while beneficial ownership registers remain in place despite being closed to the public. The second is geography: the role of the UAE is growing. There, foundations under English common law are offered by ADGM (Foundations Regulations 2017), DIFC (Foundations Law No. 3 of 2018), and RAK ICC (2019). They combine zero taxation, confidentiality, and convenience for capital management and family offices in the region (see fund management in ADGM and DIFC).
Comparison of private foundation jurisdictions
Thirteen foundation regimes are compared on nine criteria in two tables. The first covers the statute, minimum capital and mandatory participants; the second covers legal protection and registration times and what the registrar charges. Tariffs are the registrars' own published schedules; professional fees for council members, registered agents and offices are set by the market and are not in the tables.
| Jurisdiction | Statute and year | Minimum capital | Council, guardian, local official | Beneficiary register | Foundation tax |
|---|---|---|---|---|---|
| Liechtenstein | PGR Art. 552 ff., 1926; 2008 reform in force 1 April 2009 | CHF, EUR or USD 30,000 | Stiftungsrat of 2 or more, one a licensed Treuhänder (Art. 180a PGR); protector optional | Gründungsanzeige deposited; VwbP register non-public | 12.5%, minimum CHF 1,800; PVS pays the minimum only |
| Panama | Law 25 of 12 June 1995 | USD 10,000 declared | Council: a legal entity or 3 individuals; protector optional; resident agent | Charter public, reglamento private; RUBF closed (Law 129/2020) | 0% on foreign-source income; tasa única USD 400 a year |
| Jersey | Foundations (Jersey) Law 2009, from 17 July 2009 | None (Art. 7) | Council with a qualified member (registered TCB); guardian mandatory (Art. 13) | Charter public with council and endowment; regulations private; UBO data with the JFSC, non-public | 0% standard rate; 10% or 20% on specific income types |
| Guernsey | Foundations (Guernsey) Law 2012, from 7 January 2013 | None (s. 2(2)) | Council of 2 or more (s. 9(2)); guardian for purpose or disenfranchised beneficiaries (s. 10); resident agent if no licensed official (s. 12) | Register Part A public (councillors, guardian); Part B and charter confidential | 0%, taxed as a company |
| ADGM | Foundations Regulations 2017 | USD 100 (s. 9) | Council of 2 or more (s. 18); guardian optional (s. 25); registered office in ADGM, agent optional | By-laws private; UBO file with the Registration Authority, non-public | 9% above AED 375,000; family-foundation transparency on FTA application (MD 261/2024); QFZP 0% |
| DIFC | Foundations Law No. 3 of 2018 | None (Art. 27) | Council of 2 or more; guardian only for charitable or specified objects (Art. 23); agent optional (Art. 24) | Charter public, by-laws private; UBO regulations, non-public | Same federal regime as ADGM |
| RAK ICC | Foundations Regulations 2019, amended 2025 | USD 100 (Reg. 26) | Council of 2 or more (Reg. 17); guardian for charitable or specified objects (Reg. 20); registered agent mandatory (Reg. 25) | No public disclosure (Reg. 34(6)) | Same federal regime as ADGM |
| Curaçao | Stichting Particulier Fonds, Civil Code Book 2, 1998 | None | Board; notarial deed; a licensed local trust office usually acts as director | Chamber of Commerce foundation register; UBO register non-public since 8 June 2024 | Exempt from profit tax without business activity; optional 10% regime |
| Austria | Privatstiftungsgesetz 1993 | EUR 70,000 | Vorstand of 3 or more natural persons, 2 EU or EEA resident, beneficiaries excluded; Stiftungsprüfer mandatory | Firmenbuch public with the Stiftungsurkunde; Zusatzurkunde private | KöSt 23%; Zwischensteuer 27.5% from 2026; entry tax 3.5%; 27.5% KESt on distributions |
| Bahamas | Foundations Act 2004 (Ch. 369D) | USD 10,000 (s. 3(3), s. 8) | Officers or council; licensed foundation agent (s. 12(4)) | Beneficiaries not filed (s. 21); statutory confidentiality duty | No income or capital gains tax |
| Malta | Civil Code, Second Schedule, Act XIII of 2007 | EUR 1,164.69 | 1 or more administrators, MFSA-authorised; Malta contact point | Founder public; beneficiary statement may stay off the deed; UBO to the MBR | 35% company basis with refunds, or transparent trust basis by one-time election |
| Nevis | Multiform Foundations Ordinance 2004 | None | Management board of 1 or more, secretary and registered agent (ss. 17–19) | Not public | Exempt on election (s. 93) |
| Seychelles | Foundations Act 2009 | USD 1 | 1 or more councillors, founder not sole; protector optional; licensed registered agent | Charter filed without beneficiaries; ROBO held by the agent | Exempt from business tax |
| Jurisdiction | Firewall: heirship and foreign judgments | Creditor look-back | Registration time | Registrar tariff: set-up and annual | Bank signal: EU and FATF lists, Feb 2026 |
|---|---|---|---|---|---|
| Liechtenstein | No statutory firewall; Pflichtteil reaches 2 years back (§ 779 ABGB) | 1 year gratuitous, 5 years intent (Art. 65, 67, 74 RSO) | — | —; minimum tax CHF 1,800 a year | EEA member, on no list; licensed board member |
| Panama | Art. 14, Panamanian forum only | 3 years (Art. 15) | — | tasa única USD 350 in year one, USD 400 after | EU tax Annex I; off the FATF grey list since October 2023 and the EU AML list since June 2025 |
| Jersey | Art. 32 foreign law, heirship, judgments; Art. 33 | — | 5 business days standard, 2 hours expedited | GBP 205 standard (5 business days) to GBP 856 in 2 hours; GBP 220 a year, GBP 339 if TCB-administered (schedule 2026) | On no list; regulated TCB on the council |
| Guernsey | s. 37(3) heirship, s. 37(4) judgments | — | 24 hours standard, 2 hours expedited | GBP 100 in 24 hours, GBP 500 in 2 hours; GBP 525 a year | On no list; licensed fiduciary |
| ADGM | s. 29(2)–(5) heirship, foreign law, judgments | s. 30: only on a finding of insolvency or fraud | — | USD 1,000 set-up; USD 500 a year (schedule 2025) | UAE off the FATF grey list since February 2024 and the EU AML list since 2025; onshore common-law centre |
| DIFC | Arts. 14–16 | — | About 5 business days by the DIFC service timelines | Licence USD 350 a year plus confirmation statement USD 300 (ROC Table of Fees Rev. 18) | As ADGM |
| RAK ICC | Reg. 7 and 8 heirship, foreign judgments | — | — | AED 3,750 set-up; AED 2,250 a year (schedule 2026) | As ADGM, through an offshore registry with a mandatory agent |
| Curaçao | None | — | — | — | Kingdom of the Netherlands, on no list; licensed local trust office |
| Austria | None; Pflichtteil, gifts within 2 years counted (§ 782 ABGB) | — | — | — | EU member |
| Bahamas | s. 68 forced heirship not recognised | 2 years, Fraudulent Dispositions Act | 1 to 7 working days | BSD 500 a year, pro-rated by quarter of registration | Off EU Annex I since February 2024; licensed agent |
| Malta | None; Regulation 650/2012 applies | — | — | — | EU member; off the FATF grey list since June 2022 |
| Nevis | s. 46 forced heirship, s. 110 foreign judgments | — | — | USD 300 set-up; USD 300 annual return | On no EU list; agent-driven registry |
| Seychelles | Foreign forced heirship excluded | 2 years | — | USD 200 set-up; USD 200 a year | Off EU Annex II since February 2026; licensed agent |
The first of three main differences is that the regimes fall into two groups by origin. The civil-law originals, Liechtenstein, Austria, Curaçao and Panama, have no heirship firewall (Panama's Art. 14 works only in a Panamanian court) and rely instead on a licensed local body and a century of case law; the common-law adaptations, Jersey, Guernsey, ADGM, the DIFC, RAK ICC, the Bahamas, Nevis and the Seychelles, transferred firewall provisions from their trust laws and applied them to a legal person. A family whose heirs will litigate in Paris or Milan gets nothing from either: the EU court applies Regulation 650/2012 to the founder's estate regardless of what the foundation's statute says, and the Panama page shows how réduction still applies. The firewall is worth paying for where the assets, the bank and the likely forum are all in the foundation's jurisdiction, which is the UAE case for a Gulf-resident family.
The second difference is that minimum capital poorly reflects a regime's quality but reflects its positioning well. Liechtenstein's 30,000 and Austria's 70,000 are conditions for access to a supervised domestic institution; ADGM's and RAK ICC's USD 100 and the Seychelles' USD 1 signal a registry product. What distinguishes the regimes is the mandatory local official: a licensed Treuhänder on the Liechtenstein board, a TCB qualified member in Jersey, a licensed fiduciary as Guernsey resident agent, a licensed foundation agent in the Bahamas. That participant is the first assessed by a correspondent bank's compliance desk, and it is why the registrar tariff is the smallest line in the budget.
Third, the UAE trio is one federal tax regime with three registries. ADGM, the DIFC and RAK ICC share the 9% corporate tax above AED 375,000, the MD 261/2024 transparency election for a family foundation and the 0% qualifying free zone route; they differ in the registry's own published fee, in whether a registered agent is compulsory (RAK ICC yes, ADGM and DIFC no), and in the competent courts. The asset threshold that separates the DIFC from ADGM is a family-office rule and does not apply to a foundation on its own.
Choosing by Profile
| Profile | First choice | Why | Second choice |
|---|---|---|---|
| Civil-law family with European heirs and a European bank | Liechtenstein | EEA legal person readily understood by banks; § 15 Abs. 6 AStG exception for German-resident beneficiaries; licensed board | Austria only for Austrian tax residents; Curaçao for Dutch-Caribbean links |
| Asset protection with a foreseeable creditor forum inside the jurisdiction | Jersey or Guernsey | Firewall block in Art. 32 and s. 37 plus a regulated fiduciary; 2-hour incorporation | ADGM or DIFC where the assets are in the Gulf; for a hostile-creditor scenario the Cook Islands or Nevis trust, where a foundation is the weaker tool |
| Charitable or mixed purpose | Liechtenstein | STIFA supervision of charitable foundations and PVS for the private part | Jersey with a mandatory guardian; ADGM or DIFC where a guardian is compulsory for charitable objects; Malta's social-purpose rates |
| Crypto and token treasury | ADGM | Dedicated DLT Foundations Regulations 2023 and licensed custodians in the zone; 9% or transparent | Liechtenstein with a TVTG-registered custodian bank; Jersey for a token holding under a regulated TCB |
| UAE-resident family with Gulf assets | DIFC or ADGM | Foundation plus a DIFC will covers property remaining in personal ownership; firewall matches the forum | RAK ICC as the budget registry with a compulsory agent |
| Low-cost holding wrapper without a European bank | Seychelles or Nevis | USD 200–300 registrar fees, licensed agent, 2-year look-back in the Seychelles | Panama, accepting the EU Annex I listing in bank onboarding |
Worked Example: Public Levies Over Five Years
A family holding company worth EUR 15 million is to be placed under a foundation, and three options are being considered. Counting only what the registrar or the tax office publishes, five years cost: Liechtenstein CHF 9,000 in minimum tax (5 × CHF 1,800) with CHF 30,000 of capital tied up in the foundation itself; Jersey GBP 1,085 (GBP 205 standard incorporation plus 4 × GBP 220 annual confirmation); ADGM USD 3,000 (USD 1,000 set-up plus 4 × USD 500 renewal); the DIFC USD 2,950 (USD 350 licence in year one plus 4 × USD 650 licence and confirmation statement). The spread between the cheapest and the dearest is under EUR 10,000 over five years. The budget is determined by the licensed council member or qualified member, the registered office and the annual accounts, none of which appear in a tariff, and the choice of structure is determined by two questions: whose court tests the endowment, and which registry is already familiar to the family's bank.
Q/A
Does a low tax burden on the foundation mean that its founder and beneficiaries owe no tax?
No. A Liechtenstein family foundation with no economic activity qualifies for the preferential PVS regime with a minimal annual tax, and a Panamanian foundation is not taxed on foreign income by virtue of the territorial principle — but the taxes of the founder and the beneficiaries in their countries of residence do not disappear. CFC rules and income attribution norms tax the foundation's income at the level of a specific individual.
The founder wants to keep control. When is a foundation deemed a sham?
When control stops being a power and becomes disposal. Appointing and removing council members and changing the circle of beneficiaries are powers the founder may retain; but if a court or tax authority decides he manages the assets as his own, the foundation is deemed a sham and look-through is applied. A structure with no real management on site also leads to recharacterisation and additional assessments.
How does a tax authority classify a foundation if local law has no such structure?
Unpredictably, and that is a risk in its own right. Countries unfamiliar with the structure classify a foundation sometimes as a trust, sometimes as a corporation, sometimes as transparent, and the tax consequences change with the characterisation. Banks also scrutinise a foundation more strictly than an ordinary company: they want a clear purpose, source of funds and an understandable circle of beneficiaries.
Does a foundation provide confidentiality?
Only towards outsiders. A foundation almost always falls under CRS — as a Financial Institution or as a Passive NFE — and then data on the founder, council and beneficiaries goes to the tax authorities of their countries. Public access to UBO registers was closed by the EU Court of Justice on 22 November 2022 in joined cases C-37/20 and C-601/20, citing Articles 7 and 8 of the Charter, but tax and law-enforcement authorities kept it.
A Panama foundation is cheaper. Is the Liechtenstein premium worth paying?
It is, where the foundation will have to deal with banks and courts. Liechtenstein offers a century of case law under Art. 552 PGR and bank confidence; Panama offers low cost and the territorial principle, under which foreign income is not taxed; Jersey and Guernsey offer common law and mechanisms familiar to English lawyers. Where the goal is protection from creditors rather than succession, families more often take Nevis and Cook Islands trusts.
Which foundation jurisdiction has the strongest firewall against forced heirship?
The common-law adaptations: Jersey (Art. 32 of the 2009 Law), Guernsey (s. 37), ADGM (s. 29), the DIFC (Arts. 14–16), RAK ICC (Reg. 7 and 8), the Bahamas (s. 68), Nevis (s. 46 and s. 110). Each of them binds its own court and no other. Liechtenstein, Austria and Curaçao have no such clause, and Panama's Art. 14 works only before a Panamanian judge. Where the heirs or the assets are in an EU forced-heirship country, Regulation 650/2012 decides the reserved share there whatever the statute says.
Do ADGM and DIFC foundations pay the 9% UAE corporate tax?
By default a foundation is a taxable person at 0% up to AED 375,000 and 9% above. A family foundation may apply to the FTA under Ministerial Decision 261/2024 to be treated as fiscally transparent, in which case the income is attributed to the beneficiaries, and a holding foundation in the free zone may qualify for 0% as a qualifying free zone person. The three UAE registries share this federal regime; they differ only in registrar fees, agent requirements and courts.
Which minimum capital requirements are significant?
Liechtenstein (30,000 francs, euros or dollars) and Austria (EUR 70,000) are the only two with a substantive minimum; Panama and the Bahamas set USD 10,000, ADGM and RAK ICC USD 100, the Seychelles USD 1, and Jersey, Guernsey, the DIFC, Curaçao and Nevis none. The requirement that shapes the budget is the mandatory licensed official: the Treuhänder in Liechtenstein, the TCB qualified member in Jersey, the licensed fiduciary in Guernsey, the licensed foundation agent in the Bahamas.