Module IV· Regional & Structuring NotesAdvanced
Question

Explain foundation (trust) ownership of companies. Why is it relevant for PE?

Answer

A foundation is an independent legal person with no owners. Its purpose is fixed in its charter and cannot be changed at will. Classic examples are companies majority-held by their founders' charitable foundations (e.g. Bosch, Carl Zeiss).

Why relevant for PE? Foundations typically cannot be bought outright, but they regularly sell partial stakes or sub-divisions (carve-outs). Foundation sales are supervised by the relevant charitable-foundation authority and require approval.

Deep diveShow more details
AspectFoundationHolding
Ownernone (purpose-bound)shareholders/members
Sellabilityvery limitedunrestricted
Taxoften charitable (tax-exempt)normal corporate tax
  • Carve-out: the foundation sells a sub-division (e.g. Bosch's packaging-technology unit to CVC in 2019)
  • Continuation vehicle: the foundation seeks a liquidity solution without losing control
  • Mezzanine investment: operating capital without an equity stake
  • 100% buyout: almost always ruled out by the foundation's purpose
  • Selling foundation assets needs regulatory approval (slow)
  • A full sale forfeits the tax advantages

If asked about foundation structures, answer: "Foundations are untouchable for classic buyouts but regular sellers of sub-stakes. Bosch handed its packaging unit to CVC in 2019 — a typical carve-out from a foundation. The sponsor has to work with the foundation regulator and plan the closing timing accordingly."