Family foundation buys real estate and doesn't rule out selling it. For the tax office, it's speculation

The tax administration is often strict in assessing family foundations that want to abuse the right to exemption from income tax. Refusals of such a benefit result from the statutorily limited scope of economic activity of such foundations. Sometimes it is difficult to deny the tax office is right when, for example, under the pretext of conducting "rental of own real estate" (exempt from CIT), the foundation wants to include in its assets an ordinary commercially operating holiday resort.

However, one of the latest interpretations indicates that the tax authorities have gone quite far in their restrictive approach. The interpretation issued on 17 January this year by the Director of the National Revenue Information concerns a foundation. Which is only just preparing to purchase real estate. In its application to the National Revenue Information Service, it indicated that the real estates in question are an investment that is to generate income from renting them out. The foundation also indicated that it does not intend to sell them within 10 years, although it did not rule out selling them after that period.