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July 30, 2026

This guide explains the Corporate Tax treatment for Family Foundations and similar entities. It details the conditions under Article 17 that allow such entities to apply to be treated as a fiscally transparent Unincorporated Partnership. This election requires that the foundation is established for the benefit of natural persons and does not conduct a taxable Business Activity. If approved, the foundation itself is not a Taxable Person; instead, its income and assets are attributed directly to its beneficiaries, preserving the tax character of the underlying income and simplifying wealth management structures.

Taxation of Family Foundations

Corporate Tax Guide | CTGFF1

May 2025

1. Glossary

2. Introduction

2.1. Overview
2.2. Purpose of this guide
2.3. Who should read this guide?
2.4. How to use this guide
2.5. Legislative references
2.6. Status of this guide

3. What is a Family Foundation?

Corporate Tax treatment for Family Foundation N:Corporate Tax treatment for Subsidiary A:Corporate Tax treatment for Subsidiary B:

Corporate Tax treatment for the family members who are beneficiaries

Example 7: Multi-tier structure - Ownership condition not met

Corporate Tax treatment for Family Foundation C

Corporate Tax treatment for Company DCorporate Tax treatment for the family members who are beneficiaries

Example 9: Multi-tier structure (entity not wholly owned)

Corporate Tax treatment for SPV JCorporate Tax treatment of the family members who are beneficiaries

Example 11: Application of the Participation Exemption at the beneficiary level and the treatment of distributions

Distribution condition for Foundation SCorporate Tax treatment for Ms P and Mr Q

Contents