Comparing The Netherlands Antilles with Panama and Liechtenstein

• Liechtenstein offers the oldest most traditional type of foundation. The law distinguishes between several types of foundations or similar entities. The differences between them are not always obvious. Rules regulating the foundations are also vague. Liechtenstein is increasingly under suspicion of being a money laundering country. There are plans for a legal reform, but nobody knows where this will lead.

• The Panama foundation is in many regards an ameliorated copy of the Liechtenstein foundation. It is based on the Anglo-American trust system, and is considered to be far more liberal and secure than any Liechtenstein foundation.

• The Netherlands Antilles Private Foundation is a new, modern type of foundation adapted to the realities of our time and legally in accordance with international laws and agreements. The NA Private Foundation is by far the most secure, private and liberal type of foundation.

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	Liechtenstein	Panama	Netherlands Antilles
Confidentiality	Not guaranteed. Full foundation articles have to be registered in Public Registry, including name of beneficiaries and founder.	Partly. Only basic information published in Public Registry. Beneficiaries can remain anonymous.	Guaranteed. Beneficiary's and future beneficiaries' names do not have to be published in Foundation Registry. Original founder remains anonymous if a Trust Company is mentioned as founder.
Capital Requirement	30,000 SF.	10,000 USD.	6,000 USD as minimum registered capital.
Bookkeeping	Very extensive.	Moderate.	Minimal.
Fees	Usually more than 650 USD annual taxes on capital (1% of capital).	250 USD annual fees with registered capital of 10.000 USD.	40 USD annual fees with registered capital of 6000 USD.
Privacy	Not guaranteed. Supervision by government.	Guaranteed. Founder can name Supervisory Board members. No supervision by state.	Guaranteed. Founder has full control over Supervisory Board members. No supervision by state.
Beneficiaries	Restrictions concerning choice of beneficiaries, nature and amount of gifts.	No restrictions concerning choice of beneficiaries, nature and amount of gifts.	No restrictions of any nature.
Financial Activities	No business allowed. Restrictive application, subject to unclear legal interpretation.	No business allowed, but foundation can hold title to assets like corporation and act like a trust. Many types of asset management allowed.	PF can qualify as passive holding company. Asset management - widely interpreted - is not considered a business.
Nationality Requirements	At least one member of the Council must be private person with Liechtenstein nationality. Several board members needed.	No nationality requirement for board members who can be private persons or juridical persons. Only one resident director needed.	No nationality requirement for board members. Only 1 resident director is needed. (Usually trust company). Board can consist of just one member.
Capital/Assets Publication	Original and added capital has to be published.	Only basic foundation amount of 10,000 USD to be published.	No obligation to publish capital/assets at any time.
Capital Transfer	Has to be done before the registration of foundation. Added assets will always be public	Capital can be transferred after registration of foundation.	Capital can be transferred after registration of foundation.
Appeal by Creditors	Creditors of founder can appeal against transfer of assets to foundation.	Creditors can appeal against transfer until the third year of registration of foundation. If transfer takes place later, no appeal possible.	No possibility at any time for creditors to appeal against transfer of assets to foundation.
Appeal Against Inheritance Provisions	Possible if provisions violate laws of founder's country of origin.	No appeal possible because of foreign laws.	No appeal possible because of foreign laws. Only founders will counts!
Safety	Liechtenstein foundation under increased scrutiny, especially by Germany. Problems can be expected in the future. Laws not very clear and legal reform is planned with unknown result.	Can be seen as safe. Panama rejects foreign legal claims.	PF in accordance with Dutch, European and OECD regulations. Perfectly save and legal. Not subjected to any scrutiny.
Expenses, Fees	Very high notary, lawyer and administration fees.	Fees and expenses very reasonable.	Lowest fees and expenses.
Language	German a must for official papers.	Spanish translation of official papers needed.	German a must for official papers.	Spanish translation of official papers needed.	All paperwork can be done in English or Dutch.

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