Since 1. January 2017, Liechtenstein applies linking rules for dividends within corporate groups to avoid double non-taxation. Dividends arising from participations in legal persons to at least 25 % of the votes or capital shall not be exempt from income and profit tax if these dividends can be deducted as expenses in the source state (see Art. 15 para. 2 letter n of the Tax Act, Art. 48 para. 1 letter e and para. 2 letter b of the Tax Act and Art. 48 para. 3 letter a of the Tax Act).