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Family foundation — succession and taxation

Anna Kujawińska·Vice-President · Tax adviser no. 15150·6 min read

A family foundation is a way to organise succession and protect the assets of a family business — with favourable tax rules. We explain how it works, how it is taxed and for whom it makes sense.

What a family foundation is

A family foundation is a separate entity that gathers and manages assets contributed by the founder, and then pays benefits to beneficiaries (e.g. family members) under agreed rules. It separates asset ownership from day-to-day management and organises succession across generations.

Taxation — the key rules

  • As a rule, the foundation pays no ongoing CIT on gathered assets and income from permitted activity.
  • Tax (15% CIT) arises only when benefits are paid out to beneficiaries.
  • Benefits for the closest family (the zero group) are exempt from PIT.
  • The founder's contribution of assets to the foundation is tax-neutral.

For whom it makes sense

A family foundation works well for family business succession, protecting assets from fragmentation and multi-generation planning. It does require careful design — the statute, payout rules and structure — tailored to the family and the business.

In short: we will assess whether a family foundation fits your business and help design it tax-wise and organisationally.
Anna KujawińskaAK
Anna Kujawińska
Vice-President · Tax adviser no. 15150
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