Knowledge base · Structures

A foundation over a Cyprus holding company

A private-benefit foundation, here in Liechtenstein, holds a Cyprus holding company and through it the family's businesses, so the group has an owner with legal personality that outlasts each generation and a holding layer inside the EU.

Ownership chart

A foundation over a Cyprus holding companyFounderPersonLicensedcouncil memberPersonDaughterPersonSonPersonPartner'scompanyCompanyFamily foundationFoundation · LIHolding companyCompany · CYOperating companyCompany · DEJoint ventureCompany · PL
A foundation over a Cyprus holding company
  • Founder: founder of — Family foundation
  • Licensed council member: council member of — Family foundation
  • Daughter: beneficiary of — Family foundation
  • Son: beneficiary of — Family foundation
  • Family foundation owns 100% — Holding company
  • Holding company owns 100% — Operating company
  • Holding company owns 60% — Joint venture
  • Partner's company owns 40% — Joint venture

A foundation is a legal person with no shareholders. Its assets belong to it and are held for its purpose and its beneficiaries, under a deed the founder sets and a council that runs it. For families from civil-law countries it is often the natural owner of a family group: one legal person that holds the shares while generations change.

Liechtenstein’s foundation (Stiftung) is the long-established form. Its council has at least two members, at least one of them a licensed Liechtenstein professional; the founder may reserve the right to amend or revoke; and a private-benefit foundation may be deposited with the Office of Justice instead of being entered in the commercial register, so that it appears in no public record while its beneficial owners are still filed. Malta, an EU member state, offers an alternative under its Civil Code: a foundation formed by public deed before a Maltese notary and registered with the Registrar for Legal Persons, with a minimum endowment of €1,164.69, administrators authorised by the MFSA when they act by way of business, and a Malta-resident local representative where every administrator lives abroad. Cyprus has no private-foundation law, so the foundation sits above the Cyprus company rather than in Cyprus.

Below the foundation, the Cyprus holding company does what it does in any group: dividends flow up to it, it holds and sells subsidiaries, and it keeps the group’s records in the EU. Its register lists the people behind the foundation, because a foundation is never the last name in a beneficial-ownership filing.

Who is the beneficial owner

None of the people in the chart holds a share. The foundation holds 100% of the holding company, which holds all of the operating company and 60% of the joint venture, so the foundation stands behind 60% of the joint venture and controls it. A foundation has no percentage test, so the founder, the members of its council (the licensed Liechtenstein member shown here and any other) and both children as beneficiaries are beneficial owners of the holding company and of both companies below it. The partner's company holds 40% of the joint venture and has its own beneficial owners, who must be identified the same way.

Effective interest in Joint venture
PersonThrough sharesThrough a role
Founder—founder · Family foundation (60%)
Licensed council member—council · Family foundation (60%)
Daughter—beneficiary · Family foundation (60%)
Son—beneficiary · Family foundation (60%)
Structures

What each layer files and keeps

  1. 01

    The foundation

    The foundation deed and by-laws, with any supplementary by-laws; its entry in the commercial register or, for a private-benefit foundation, its deposit with the Office of Justice; its filing in the register of beneficial owners within 30 days; council resolutions; the source of the founder's endowment, at least 30,000 in Swiss francs, euros or dollars; and an annual tax return at 12.5%, unless private-asset-structure status limits it to the CHF 1,800 minimum tax.

  2. 02

    The Cyprus holding company

    Registers of members and directors; the beneficial-ownership filing naming the founder, the council members and the beneficiaries, updated within 45 days of a change and confirmed between 1 October and 31 December each year; audited IFRS accounts with the HE32 annual return; the tax return; and board minutes showing decisions taken in Cyprus.

  3. 03

    The operating company and the joint venture

    Their own local accounts, filings and beneficial-ownership entries, each naming the people behind the foundation, with dividend resolutions and the joint-venture agreement with the partner.

What to watch

  • Every register in the chain — Liechtenstein's, Cyprus's and each subsidiary's — names the same founder, council members and beneficiaries; a filing that stops at the foundation is incomplete
  • The council takes the foundation's decisions; at least one member is a licensed Liechtenstein professional with due-diligence duties, and any rights the founder reserves are written into the deed
  • How the founder's and the beneficiaries' home countries tax the foundation depends on how much control the founder keeps in practice
  • The holding company needs real decisions in Cyprus; banks and treaty partners look for board meetings there, not only a registered office

What the dossier keeps

  • The foundation deed, by-laws and any letter of wishes, with the register or deposit confirmation
  • The chart from the foundation to every company, with the evidence for each holding and the joint-venture agreement
  • Every entity's beneficial-ownership filing, reconciled with the others
  • The calendar of every filing in Liechtenstein, in Cyprus and in each subsidiary's country

Jurisdictions in this structure

General information, not advice. Facts are stated as of the date on each page. Law, lists and rates change; the professional who acts for the entity confirms what applies to it. Chrysos performs no regulated act and gives no legal or tax advice.

Facts as of 30 October 2026