Current ownership
Shares, partnership interests, voting rights, debt and control routes are documented first.
Concept Logic
Foundation, holding and GmbH & Co. KG as a structured review path.
A foundation-holding structure with a GmbH & Co. KG layer can only be assessed properly if ownership, management, partnership interests, functional allocation, exit tax and documentation are reviewed together.
Why the combination is complex
- The foundation layer may organise control, ownership stability and succession.
- The holding layer may organise participations, distributions and reinvestment.
- The GmbH & Co. KG layer may affect partnership income, functional allocation and relocation analysis.
- Each layer must be explainable on its own and as part of the overall target structure.
Review path
Transfer steps
Contribution, share-for-share exchange, sale, donation or endowment steps are ordered by tax consequence.
Relocation link
Partnership interests and shareholdings are assessed before persons or functions move.
Documentation
Resolutions, contracts, valuations, funds flow, governance records and bank materials must align.
Output
- Target structure diagram with ownership and control routes.
- Tax review map for transfer, exit, income and succession effects.
- Document and implementation sequence.
- List of issues requiring admitted local professionals.