Family foundation
A dedicated asset vehicle for family governance, succession and long-term ownership. Key points include founder intent, beneficiaries, governance, transfer route, valuation and possible inheritance-tax consequences.
Glossary & structuring knowledge
Complex tax terms become useful only when they are placed in the right review path.
This glossary gives international advisers, banks and entrepreneurs a common vocabulary for German and cross-border structuring discussions. It is not a legal opinion, but it helps structure the first conversation.
Foundation, holding and ownership architecture
The same word can trigger very different tax, legal and banking questions depending on facts, jurisdiction and sequence.
Foundation as holding layer
A foundation can hold participations, but the tax result depends on how assets are transferred, how distributions are documented and whether the structure is bankable.
GmbH & Co. KG
A partnership layer can affect business income, functional allocation, permanent establishment analysis and relocation planning.
Ownership architecture
The operating logic of family, management, control rights, information rights, distributions and reinvestment policy.
Tax concepts that commonly matter
Relocation and hidden reserves
A move of residence or a transfer of shares can make hidden reserves visible for German tax purposes. Shareholdings, partnership interests, return rules and timing must be mapped.
Controlled foreign company risk
Foreign companies with low taxation, passive income or weak substance may create attribution risk. Control, activity, substance and documentation must be reviewed together.
Substitute inheritance tax
German family foundations may face a deemed inheritance event after a 30-year period. Valuation, liquidity and beneficiary design should therefore be part of the initial structure.
Source of wealth and funds
Banks need a coherent explanation of wealth creation, transaction funding, beneficial ownership, purpose and expected flows.
Full-text topic matrix from 1,606 articles
The new full-text source is used as a complete topic map. No third-party articles are reproduced; the full search and term landscape is translated into SLA's own review paths.
Relocation, return and international tax
The source shows high demand around exit tax, return moves, Cyprus, Dubai, treaties, withholding tax, second passports and international residence. For SLA this becomes a review path for German exit tax, effective management, CFC, treaties, substance and bankability.
Holding, GmbH and distribution logic
Holding and GmbH topics dominate the source. Relevant points include acquisition, contribution, shareholder loans, distributions, retained earnings, hidden profit distributions, financing and exit readiness.
Reorganisation, contribution and book-value rollovers
Reorganisation topics include sole businesses, GmbH conversions, double holdings, share-for-share exchanges, book-value applications, real estate transfer tax and lock-up periods. The value is in the right sequence.
Foundation, succession and asset locking
The source reflects demand for foundation benefits, family foundations, wealth succession, gifts, inheritance tax and long-term ownership order. SLA translates this into governance, valuation, liquidity and control rights.
Real estate, holdings and asset management
Real estate questions range from business premises, foreign owners, speculation periods, transfer tax and real estate GmbHs to transfers. Financing, use and tax status are decisive for entrepreneur structures.
Tax audits, voluntary disclosure and procedure
Procedure and tax offence topics show that structures must not only be planned, but later proven. Documentation, cooperation, assessments, appeals and audits belong in the ongoing care process.
VAT, grouping and service relationships
VAT is often underestimated in structuring projects. Management fees, cost allocations, input VAT, grouping, place of supply, invoice route and actual service provision need to match.
Crypto, digital assets and evidence
Crypto topics touch holding periods, documentation, wallet history, relocation, banking, voluntary disclosure, company assets and source of funds. SLA focuses on auditable origin and transaction documentation.
M&A, exits and valuation
Exit, acquisition and valuation questions connect price, ownership structure, holding layers, relocation, earn-outs, due diligence and tax clauses. The aim is a bankable and tax-reviewable target picture before transaction pressure.
GmbH & Co. KG, split businesses and partnerships
Partnerships trigger special review points around partnership interests, special business assets, demergers, split-business structures, losses and relocation. Tax logic and constitutional documents must match closely.
How the glossary should be used
- Start with the event: relocation, contribution, foundation, sale, bank onboarding, succession or restructuring.
- Separate facts, assumptions, open tax questions and local-law questions.
- Use the glossary as an intake layer; material consequences require a structured memo, risk matrix or ruling strategy.
- Reserved legal or tax tasks are handled by admitted professionals in the relevant jurisdiction.