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July 30, 2026
This article allows a Family Foundation to apply to be treated as an Unincorporated Partnership for tax purposes, thereby achieving fiscal transparency. To qualify, the foundation must be established for the benefit of identifiable natural persons or a public benefit entity. Its principal activity must be managing assets and funds, and it must not conduct a business activity that would be taxable if undertaken directly by its founder or beneficiaries. Crucially, the main purpose cannot be tax avoidance. If the application is approved, the foundation is treated as transparent, with tax implications flowing through to its members.
Chapter 4 - Taxable Person and Corporate Tax Base
Article 17 - Family Foundation
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