Before relocation or sale
Restructuring before a relocation or exit must be prepared in the correct order.
Holding & Reorganisation
Holding structures and reorganisations need the right tax sequence.
Contributions, share-for-share exchanges, partnerships, holdings or foundations should not be planned in isolation. Sequence, valuation, lock-up periods, exit taxation, documentation and bankability of the overall structure matter.
When it becomes relevant
Bundling participations
A holding can organise shareholdings but does not replace tax, valuation and substance review.
Foundation or family governance
The pre-structure should be reviewed before assets are transferred into a foundation or succession vehicle.
Review questions
- Which assets, participations, businesses or partnership interests are to be contributed?
- Which valuation approach and tax-neutral treatment may be available?
- Which lock-up periods, evidence duties, valuation questions and exit risks apply?
- Is a GmbH, holding company, partnership, foundation or foreign structure commercially justified?
- How are contracts, resolutions, valuations, charts and funds flow documented?
Outcome
- Structure comparison with sequence, risks and open review points.
- Implementation roadmap for advisers, notary, bank, registers and entities.
- Document list for valuation, contracts, resolutions and tax evidence.