Private Foundations Compared in 2026: Liechtenstein, Nevis, Panama and the Jurisdictions That Still Matter

Status as of 23 October 2026: based on the Liechtenstein Persons and Companies Act (PGR, Article 552, in force since 1 April 2009), the Nevis Multiform Foundations Ordinance 2004 (revised edition as at 31 December 2017), the Panama Private Interest Foundations Law (Law 25 of 12 June 1995) and Law 129 of 17 March 2020 on the beneficial ownership registry, the Foundations (Jersey) Law 2009, the Foundations (Guernsey) Law 2012, the Bahamas Foundations Act 2004, the Second Schedule to the Maltese Civil Code, the Austrian Private Foundations Act 1993, the German Foreign Tax Act (§ 15 AStG) and Inheritance and Gift Tax Act (ErbStG), the Romanian Civil Code, the Council of the EU conclusions of 9 October 2026 on the list of non-cooperative jurisdictions and FATF public statements. We will update this guide when the law or official practice changes.

A trust is a promise. A foundation is a person. That single difference explains why families from Zurich to Bucharest, from Munich to Buenos Aires, have used private foundations for a century, and why the choice between them still matters in 2026.

When the 23 October guide on Cook Islands, Nevis and US asset protection trusts went live, the most frequent question was simple: what if my country does not understand trusts at all? For a German, a Romanian, an Austrian or a Latin American family, the honest answer is often a foundation. Civil law judges, notaries and tax officials know what a legal person is. They do not always know what to do with a trustee who owns assets for someone else.

This is stage two of our asset protection series. We compare the foundation jurisdictions that still carry weight: Liechtenstein, the original; Nevis, the hybrid; Panama, the famous one that is not what it used to be; and the serious alternatives in Jersey, Guernsey, Malta, the Bahamas, the Cook Islands, Seychelles and Austria. For years this comparison was made in family offices for families with nine-figure balance sheets. Until now. Through Bogdan and ENCC, you can sit at the same table, at the scale of your own life.

One warning comes first, because it decides everything else. A foundation does not choose its tax treatment. The country where the founder and the beneficiaries live does. Germany has a dedicated anti-avoidance rule for foreign family foundations. Romania has no private family foundation of its own and no settled practice for taxing distributions from a foreign one. A foundation can be a fortress against creditors and still be a tax problem at home. Everything below is built around that warning.

Key points

• A foundation is a legal person with no owners. The founder gives assets away to an entity that belongs to itself and serves a purpose or beneficiaries. That is its strength and its discipline.
• Liechtenstein is the reference. A modern statute since 2009, deep case law, EEA membership, strong banks and a supervisory system that civil law countries trust.
• Nevis is the most flexible. Its Multiform Foundation can be a foundation, a trust, a company or a partnership, and can change form. It also has the strongest creditor rules in this comparison. We cover it in a separate deep dive.
• Panama has changed. After the Panama Papers, two FATF grey listings and six years on the EU blacklist, Panama built a beneficial ownership registry and reformed its territorial tax regime. On 9 October 2026 the EU moved it off Annex I. It is usable again, but it is not the discreet tool of 2010.
• Jersey, Guernsey and Malta are the onshore-quality options. Strong courts, high regulatory standards, good banking. Less aggressive creditor protection.
• Timing is the protection. Every jurisdiction protects early, calm transfers far better than transfers made when a claim is already visible.
• Control is the weak point. A founder who keeps every lever gives a court, and a tax office, a reason to treat the assets as still his.
• Everything is reported. Every jurisdiction in this guide exchanges financial account information under the Common Reporting Standard, and foundations are reported much like trusts.

Foundation or trust: the legal nature

A trust is a relationship. The trustee owns the assets and holds them for the beneficiaries under a deed. There is no separate legal person. The common law built it over centuries through the courts of equity.

A foundation is an entity. The founder endows assets to a new legal person with its own name, its own seat and its own organs. Once endowed, the assets belong to the foundation. Not to the founder, not to the council, not to the beneficiaries. The foundation acts through its foundation council, which is closer to a board of directors than to a trustee.

That difference has practical consequences:

• Recognition. A foundation is recognised as a legal person almost everywhere, including civil law countries that never signed the Hague Trusts Convention. Germany and Romania are both outside that Convention.
• Contracts and banking. The foundation signs in its own name. Banks open accounts for it as for a company, with the council as signatories and the beneficial owners identified.
• Litigation. A creditor sues the foundation, not a trustee personally. The foundation's own domestic court decides on its validity.
• Purpose. A foundation may serve family members, a purpose, or both. Most modern statutes allow a private benefit foundation, which is what families use.

The price of that clarity is separation. The assets genuinely leave the founder. A founder who wants to keep everything under his own hand should not build a foundation. He should keep a company.

Founder rights, the council and the protector

The founder's reserved rights are the dial between control and protection. Most foundation laws allow the founder to reserve rights: to amend the statutes, to revoke the foundation, to appoint or remove council members, to change beneficiaries. In Liechtenstein, Article 552 § 30 PGR allows the founder to reserve revocation and amendment rights in the foundation deed. Nevis, Panama, Jersey, Guernsey and the Bahamas all allow comparable reservations.

Every reserved right is also a door. Creditors, divorce courts and tax authorities look first at what the founder can still do. If the founder can revoke and take everything back, many courts will treat the revocation right as an asset of the founder that his creditors can reach. Liechtenstein practice treats the revocation right as reachable in enforcement against the founder, and the period for challenging his transfer does not effectively start while he keeps that right. The German Federal Fiscal Court made the same point from the tax side in 2007: where a founder kept full control over a Liechtenstein foundation, the transfer was not a completed gift, because the assets had not left him (BFH, judgment of 28 June 2007, II R 21/05).

The council is where the real decisions sit. In serious structures the council includes at least one licensed professional in the foundation's jurisdiction. Liechtenstein requires a qualified member for foundations that are not registered under supervision, and most offshore statutes require a local registered agent or secretary.

The protector, often called a guardian or supervisory board, watches the council. It can veto certain decisions, replace council members or approve distributions. In Jersey the guardian is a mandatory organ under the Foundations (Jersey) Law 2009. In Nevis the supervisory board is defined in the Ordinance itself. A protector is useful when he is independent. A protector who is the founder under another name is a liability.

Beneficiaries: who benefits and what they can claim

Beneficiaries of a discretionary foundation have expectations, not ownership. In most private foundations the council decides who receives what and when. A beneficiary has no claim until the council decides. That is a key protection: a beneficiary's creditor cannot seize what the beneficiary does not yet have.

Information rights differ. Liechtenstein grants beneficiaries certain information rights unless the founder is the ultimate beneficiary or a supervisory body has been installed. Jersey and Guernsey allow the charter to limit information rights. Panama traditionally gave beneficiaries few rights unless the regulations said otherwise.

Founder as beneficiary. Many jurisdictions allow the founder to be a beneficiary. It is legal. It is also the classic weak point: a self-benefiting founder with reserved rights will struggle to convince any court that the assets are no longer his.

Creditors and challenge periods

No jurisdiction protects a transfer made to defeat a known creditor. What differs is the burden of proof, the time window and the court that decides.

• Liechtenstein. Creditors of the founder can challenge gratuitous transfers to a foundation under Article 552 § 38 PGR and the Liechtenstein law on legal remedies. In general, ordinary gratuitous transfers are exposed for a limited period before enforcement, and transfers made with intent to defraud are exposed for longer, with an outer time limit. Practitioner literature commonly describes the outer limit as five years from the transfer. The precise article references and windows are flagged for review in our sources.
• Nevis. A creditor must prove beyond reasonable doubt that the founder intended to defraud him and was made insolvent by the transfer. A transfer made more than one year after the creditor's cause of action arose is not treated as fraudulent against him. A creditor whose cause of action arose earlier must sue within six months of the transfer. Before suing the foundation, a creditor must post a bond of 50,000 US dollars (Multiform Foundations Ordinance, sections 83 and 108).
• Panama. Law 25 of 1995 protects foundation assets from claims against the founder or beneficiaries, but allows transfers made in fraud of creditors to be challenged within a limitation period that the law sets at three years from the transfer (Article 11, flagged for review).
• Jersey, Guernsey, Malta, Bahamas. Each has its own firewall and limitation rules. As a rule, they apply higher standards of court scrutiny and give creditors more room than Nevis or the Cook Islands.
• Cook Islands. The Foundations Act 2012 follows the logic of the International Trusts Act: short windows, a high burden of proof and no enforcement of foreign judgments.

Fact, inference and our view. The fact is that the statutes differ widely. The inference is that a creditor who already holds a judgment will look for the weakest link, usually the founder himself, not the foundation. Our view is simple: a foundation funded early, by a solvent founder, with a genuinely independent council, is one of the most respected tools families have. A foundation funded after the letter from the lawyer arrives is a confession.

Forced heirship firewalls

In much of continental Europe, children have a reserved share that cannot be removed by will. In Germany it is the Pflichtteil. In Romania it is the rezerva succesorală under Articles 1086 and following of the Civil Code. In Austria, France, Spain and Italy similar rules apply.

Foundation laws answer with firewalls. Nevis section 46 states that no foundation and no transfer to it shall be void or voidable by reference to foreign law, including heirship rights. Panama's Law 25 contains a similar rule against foreign heirship claims. Jersey, Guernsey, the Bahamas and the Cook Islands have firewall provisions in their foundation or trust legislation.

A firewall works inside its own jurisdiction. It tells the local court to ignore the foreign claim. It does not stop a German court from ordering the German heir's sibling to pay a top-up claim from other assets, and it does not stop the German tax office from taxing the transfer. In Germany, § 2325 BGB allows a compulsory heir to claim a top-up based on gifts made in the ten years before death, reduced year by year, and the Federal Court of Justice has held that this period does not start while the donor keeps the economic benefit of the gift. A foundation that the founder still effectively controls may therefore never start the clock.

Our view. For a family that wants to treat children fairly but differently, a foundation is a strong governance tool. As a tool to disinherit a child, it invites litigation in two countries and protects less than its marketing suggests.

Registration, beneficial ownership and transparency

The secrecy era is over. That is not a complaint. It is a fact that every serious structure now starts from.

• Liechtenstein. Private benefit foundations that do not run a commercial business are not entered in the public commercial register. They deposit a formation notice with the Office of Justice within 30 days (Article 552 § 20 PGR), confirmed by a licensed Liechtenstein professional. Beneficial owners are recorded in the Liechtenstein register of beneficial owners, accessible to authorities and obliged entities.
• Nevis. The foundation is registered with the Registrar of Foundations. Filed documents are confidential under section 113 of the Ordinance, and court proceedings are heard in camera. Registered agents must hold beneficial ownership information and provide it to the authorities.
• Panama. Foundations are registered in the Public Registry. Since Law 129 of 2020, registered agents must file beneficial owner information in a central registry, the Registro Único de Beneficiarios Finales, which is not public but is available to competent authorities.
• Jersey and Guernsey. Foundations are registered, and beneficial ownership is held in central registers that are available to authorities.
• EU member states. Malta and Austria are bound by the EU anti-money laundering rules on beneficial ownership registers. Since the Court of Justice of the EU ruled on 22 November 2022 (cases C-37/20 and C-601/20) that general public access was disproportionate, access has been restricted to those with a legitimate interest.

CRS and automatic exchange

Foundations are inside the Common Reporting Standard. The OECD Commentary treats foundations broadly like trusts. A foundation managed by a financial institution is usually itself a reporting financial institution and reports its founder, council members, protector and beneficiaries who receive distributions. A foundation that is a passive entity is reported by its bank, which looks through to its controlling persons.

Every jurisdiction in this guide participates in CRS. Liechtenstein, Panama, St Kitts and Nevis, Jersey, Guernsey, Malta, the Bahamas, the Cook Islands, Seychelles and Austria all exchange information. The United States is the notable exception, as covered in our trust guide.

What this means in practice. The tax office where you live will receive data on the foundation's accounts. A foundation is a tool for protection, governance and succession. It is not a tool for being invisible, and anyone selling it that way is selling a criminal problem.

Panama: what changed

The Panama most people remember is gone. Before 2016, a Panamanian private interest foundation was a cheap, fast, discreet vehicle. It was sold in thousands by law firms whose names became headlines.

What happened.

• April 2016, the Panama Papers. The leak of one law firm's records exposed how many structures were used to hide assets from tax authorities. Panama's reputation took damage that its legal system did not deserve in full, but that its practice had earned.
• FATF grey list, twice. Panama was placed under increased monitoring by the FATF from 2014 to February 2016, and again from June 2019 until October 2023.
• EU blacklist. Panama was on Annex I of the EU list of non-cooperative jurisdictions from February 2020. The Council found deficiencies in exchange of information and, from 2021, a harmful foreign source income exemption regime. On 9 October 2026 the Council removed Panama from Annex I and moved it to Annex II, after Panama introduced economic substance requirements and was granted a new in-depth review by the OECD Global Forum, which EY reports is scheduled for the first quarter of 2027.
• Beneficial ownership registry. Law 129 of 2020 created the central registry described above. Registered agents now carry real obligations.
• Territorial taxation. Panama still taxes on a territorial basis: income from sources outside Panama is in principle not taxed there. The 2026 substance rules narrow how this applies to entities that earn certain foreign income without substance in Panama.

Our view. Panama is usable again for a family with Latin American ties, Spanish-speaking heirs or assets in the region. For a European family, it carries a reputational cost with banks that has eased, not vanished. Expect enhanced due diligence. Keep watching the February 2027 EU update and the Global Forum review.

The other jurisdictions that still matter

Jersey (Foundations (Jersey) Law 2009). A Crown Dependency with a strong court and a world-class trust industry. A foundation must have a qualified member on its council, licensed by the Jersey Financial Services Commission, and a guardian. Banking access is excellent. Creditor protection relies on Jersey firewall and limitation rules rather than on extreme barriers.

Guernsey (Foundations (Guernsey) Law 2012). Similar in quality to Jersey, with a guardian requirement in most cases and a reputation for careful drafting. Good for families who want onshore-level governance with offshore neutrality.

Malta (Second Schedule to the Civil Code). An EU member with a civil law foundation that can be private benefit. EU membership helps with recognition and banking, and it brings EU anti-money laundering and beneficial ownership rules. Malta also has trust law, so families can compare both inside one legal system.

Bahamas (Foundations Act 2004). A mature financial centre with strong firewalls and a foundation designed to compete with Liechtenstein. Better for families with American or Caribbean ties.

Cook Islands (Foundations Act 2012). The foundation sibling of the world's toughest trust law. Rare in practice, but strong on paper for founders who prefer a legal person to a trust.

Seychelles (Foundations Act 2009). Low cost and flexible, but banking acceptance is weaker. We use Seychelles rarely and only when the banking plan is clear first.

Austria (Privatstiftungsgesetz 1993). A domestic private foundation that Austrian families use widely. The founder can reserve strong rights, and Austria has its own tax regime for foundation transfers and distributions. Relevant mainly for people resident in Austria.

Netherlands stichting. Often marketed as a foundation option. A Dutch stichting may not make distributions to its founders or board members, and to others only for idealistic or social purposes, so it is not a family wealth vehicle. Its main legitimate use in structuring is as an administration office holding shares and issuing depositary receipts (STAK). We mention it so that nobody buys the wrong tool.

The comparison matrix

Liechtenstein

• Legal nature: private benefit foundation, legal person (Article 552 PGR).
• Founder control: revocation and amendment rights can be reserved; every reserved right weakens protection.
• Protector or supervision: optional supervisory body; qualified Liechtenstein council member required.
• Creditor challenge: limited window for gratuitous transfers, longer for intent to defraud (flagged).
• Heirship: time limits on top-up claims under Liechtenstein law; German claims remain at home.
• Transparency: formation notice deposited, not public; beneficial owners register for authorities.
• CRS: yes.
• Banking: strongest in this comparison, with Liechtenstein and Swiss banks.

Nevis

• Legal nature: Multiform Foundation; can be stated as a foundation, trust, company or partnership.
• Founder control: wide freedom in the constitution; management board and supervisory board.
• Creditor challenge: proof beyond reasonable doubt, one year and six months windows, 50,000 US dollar bond.
• Heirship: statutory firewall (section 46).
• Transparency: confidential register; proceedings in camera; agent holds beneficial ownership data.
• CRS: yes.
• Banking: possible but demanding; usually banked outside Nevis.

Panama

• Legal nature: private interest foundation (Law 25 of 1995).
• Founder control: reservations possible; council and optional protector.
• Creditor challenge: fraudulent transfers challengeable within the statutory window (flagged).
• Heirship: statutory protection against foreign heirship claims.
• Transparency: public registry for the foundation; central beneficial owner registry for authorities since 2020.
• CRS: yes.
• Banking: improving after the EU delisting; enhanced due diligence still common.

Jersey and Guernsey

• Legal nature: foundation, legal person.
• Founder control: moderate; qualified council member and guardian.
• Creditor challenge: local limitation and firewall rules; strong, careful courts.
• Heirship: firewall provisions.
• Transparency: registered; central beneficial ownership registers for authorities.
• CRS: yes.
• Banking: excellent.

Malta

• Legal nature: civil law foundation, EU member state.
• Founder control: moderate; EU rules apply in full.
• Creditor challenge: Maltese civil law rules on fraudulent transfers.
• Heirship: EU succession rules and Maltese law interact; review case by case.
• Transparency: EU beneficial ownership register, legitimate interest access.
• CRS: yes, plus EU directives.
• Banking: good inside the EU.

Bahamas, Cook Islands, Seychelles

• Legal nature: foundation, legal person.
• Founder control: flexible.
• Creditor challenge: strong firewalls; Cook Islands the strictest.
• Transparency: registered; agent held beneficial ownership data.
• CRS: yes.
• Banking: Bahamas good; Cook Islands and Seychelles harder.

Costs

Costs depend on the jurisdiction, the council members, the drafting, the assets and the bank. We do not publish provider prices. We compare written quotes from licensed partners for your case. Statutory minimum capital is a known fact: a Liechtenstein foundation needs at least 30,000 Swiss francs, euros or US dollars (Article 552 § 5 PGR). Other jurisdictions have their own minimums or none.

The tax angle: residence decides

The foundation's home country is rarely the problem. Liechtenstein taxes foundations under its own tax act, and a private asset structure that only manages its own assets pays the minimum tax, as covered in our Liechtenstein foundation and banking guide. Nevis exempts a Multiform Foundation from Nevis tax if it deals only with persons not resident in Nevis (section 93). Panama taxes territorially.

The problem is the founder's home country.

Germany

• Transfer. An endowment to a foundation is a taxable gift under § 7(1) No. 8 ErbStG. For foreign foundations, practice applies the least favourable tax class (class III), because the favourable relationship rule in § 15(2) ErbStG applies to family foundations established in Germany.
• Running income. § 15 AStG attributes the income of a foreign family foundation to the founder, if he is resident in Germany, or otherwise to the resident beneficiaries. There is an exception for foundations in the EU or EEA, such as Liechtenstein, if the assets are legally and factually removed from the founder and the beneficiaries and there is an information exchange with Germany (§ 15(6) AStG).
• Control. If the founder keeps full control, the BFH treats the transfer as not completed, with the result that the assets remain his for tax purposes.
• Distributions. Distributions to German residents are generally taxable; the exact classification depends on the structure and is a question for your German tax adviser.

Romania

• No domestic equivalent. Romanian foundations under Government Ordinance 26/2000 serve general or community interests. There is no private family foundation in Romanian law.
• Fiducia. The Civil Code (Articles 773 and following) provides fiducia, which is closer to a trust than to a foundation and comes with its own transparency rules.
• Distributions. The Fiscal Code does not contain a specific regime for distributions from a foreign private foundation. Classification may depend on the foundation's form and the beneficiary's rights, and practice is unsettled. This is a question for a Romanian tax adviser before any transfer.
• Heirs. The rezerva succesorală and the rules on reducing excessive gifts apply to the Romanian estate regardless of the foreign foundation's firewall.

Cyprus and other bases

For families who move, the analysis changes with residence. If you are considering Cyprus, read Cyprus asset protection: what Cyprus does not do first. A move changes which rules apply. It does not erase the past.

Fact, inference and our view. The fact is that the home country's rules apply to its residents, whatever the foundation's law says. The inference is that the best jurisdiction for a German family and the best jurisdiction for a Romanian family may differ. Our view: choose the foundation jurisdiction last, after the residence and the tax analysis, never first.

Banking acceptability

A foundation without a bank is an idea. Banks decide, more than statutes, which structures work. In our experience:

• Liechtenstein and Swiss banks know Liechtenstein foundations best and expect a clean source of wealth file and a real council.
• Jersey and Guernsey foundations are widely accepted by private banks in London, Switzerland and Singapore.
• Nevis and Panama foundations can be banked, but expect longer onboarding and more questions about purpose and substance.
• Seychelles and Cook Islands foundations are harder to bank and need a plan before formation.

For the banking stack around a structure, read offshore banking operations.

Common mistakes

• Choosing by brochure. The jurisdiction with the strongest creditor rules may be the weakest choice for a German resident.
• Keeping every lever. Reserved rights feel safe. To a court, they look like ownership.
• Funding late. Transfers after a claim is visible are the easiest to challenge.
• Ignoring heirs. A foundation that disinherits a child invites litigation in the child's country.
• Ignoring reporting. CRS data arrives at the home tax office whether the founder declares or not.
• Forgetting the bank. A structure that no bank will open an account for is a cost, not a protection.

How we build it with you

1. Map. Assets, residence, family, risks and timelines.
2. Test. Is a foundation the right tool, or is a trust, a company or a simpler arrangement better?
3. Compare. Two or three jurisdictions, with written opinions from licensed lawyers and tax advisers.
4. Build. Statutes, by-laws, council, protector, bank.
5. Run. Annual reviews, distributions, reporting, changes of residence.

FAQ

Is a foundation better than a trust?

Neither is better in general. A foundation is often easier for civil law countries such as Germany and Romania to recognise, because it is a legal person. A trust can be more flexible and, in the Cook Islands or Nevis, stronger against creditors.

Can I be the founder and a beneficiary?

In most jurisdictions, yes. It is also the most common weak point. The more you benefit and control, the more a court or tax office will treat the assets as yours.

Is Panama still usable in 2026?

Yes, with care. Panama left the EU list of non-cooperative jurisdictions on 9 October 2026 and remains under EU monitoring pending a Global Forum review. Banks still apply enhanced due diligence.

Will my tax office know about my foundation?

Yes. Every jurisdiction in this guide exchanges information under CRS. Plan for full transparency.

Does a foundation protect against forced heirship?

Inside the foundation's own jurisdiction, often yes. In your home country, heirs can still claim against your estate and, in Germany, against recipients of gifts. A firewall is not a shield abroad.

Which jurisdiction suits a German resident?

Often an EU or EEA foundation, such as Liechtenstein, because § 15(6) AStG offers a route out of attribution if the assets are genuinely removed from your control. This needs a German tax opinion.

Which jurisdiction suits a Romanian resident?

There is no settled answer, because Romanian practice on distributions from foreign foundations is unsettled. We start with the Romanian tax analysis and choose the jurisdiction afterwards.

Where can I read more about Nevis?

Our deep dive on the Nevis Multiform Foundation explains how one entity can be a foundation, a trust, a company or a partnership.

Next steps

For a trust comparison, read Cook Islands trust vs Nevis trust vs US DAPT. For Liechtenstein tax and banking in detail, read Liechtenstein foundation and banking. The companion guide on the Nevis Multiform Foundation goes deep on the most flexible foundation in this comparison. For the wider picture, read asset protection and privacy. All guides are on the English blog.

Sources

• Liechtenstein, Personen- und Gesellschaftsrecht (PGR), Article 552 (Stiftungsrecht): https://www.gesetze.li/konso/1926004000
• Liechtenstein Office of Justice, foundations: https://www.llv.li/de/landesverwaltung/amt-fuer-justiz
• Gasser Partner, creditor protection of Liechtenstein foundations (Trusts & Trustees, 2014): https://gasserpartner.com/storage/publikationen/artikel-2014/how-to-protect-the-assets-trust_trustees.pdf
• Nevis Multiform Foundations Ordinance, Cap. 7.08(N), revised edition as at 31 December 2017: https://www.nevisfsrc.com/wp-content/uploads/2023/06/Ch-07.08N-Multi-form-Foundations-Ord.pdf
• Nevis Financial Services Regulatory Commission, foundations: https://www.nevisfsrc.com/services/foundations/
• Panama, Law 25 of 12 June 1995 on private interest foundations: https://www.gacetaoficial.gob.pa/
• Panama, Law 129 of 17 March 2020, beneficial owner registry: https://www.gacetaoficial.gob.pa/
• Council of the EU, press release of 9 October 2026 on the EU list of non-cooperative jurisdictions: https://www.consilium.europa.eu/en/press/press-releases/2026/10/09/taxation-council-updates-the-eu-list-of-non-cooperative-jurisdictions-for-tax-purposes/
• EY Tax News, EU revised list of 9 October 2026: https://taxnews.ey.com/news/2026-2170-eu-issues-revised-list-of-non-cooperative-jurisdictions-for-tax-purposes
• FATF, jurisdictions under increased monitoring: https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html
• Foundations (Jersey) Law 2009: https://www.jerseylaw.je/laws/current/l_23_2009
• Foundations (Guernsey) Law 2012: https://www.guernseylegalresources.gg/
• Bahamas Foundations Act 2004: https://laws.bahamas.gov.bs/
• Austria, Privatstiftungsgesetz: https://www.ris.bka.gv.at/GeltendeFassung.wxe?Abfrage=Bundesnormen&Gesetzesnummer=10003058
• Netherlands Civil Code, Book 2, Article 285: https://wetten.overheid.nl/BWBR0003045/
• Court of Justice of the EU, judgment of 22 November 2022, C-37/20 and C-601/20: https://curia.europa.eu/juris/liste.jsf?num=C-37/20
• OECD, Common Reporting Standard and Commentary: https://www.oecd.org/tax/automatic-exchange/common-reporting-standard/
• Germany, Außensteuergesetz, § 15: https://www.gesetze-im-internet.de/astg/__15.html
• Germany, Erbschaftsteuer- und Schenkungsteuergesetz, §§ 7 and 15: https://www.gesetze-im-internet.de/erbstg_1974/__15.html
• Germany, Bürgerliches Gesetzbuch, § 2325: https://www.gesetze-im-internet.de/bgb/__2325.html
• BFH, judgment of 28 June 2007, II R 21/05: https://www.bundesfinanzhof.de/
• Romania, Civil Code (Law 287/2009): https://legislatie.just.ro/Public/DetaliiDocument/109884
• Romania, Government Ordinance 26/2000 on associations and foundations: https://legislatie.just.ro/Public/DetaliiDocument/20689

Verified on 23 October 2026.

Cover photo: Vaduz and the Rhine valley, Liechtenstein. Photo: zpunout, Wikimedia Commons, CC BY-SA 3.0, cropped.