Planned amendments include:

• introducing a temporary (3-year) exclusion from the tax exemption (i.e. a deferral of taxation until a benefit is paid to a beneficiary) on income derived from the disposal of assets contributed or transferred to a family foundation. This measure is intended to prevent the contribution of assets (e.g., shares or stocks) to a family foundation solely for their prompt disposal under the tax rules applicable to family foundations;

• subjecting family foundations to taxation in connection with their participation in a controlled foreign company (CFC),

• clarifying the rules for taxing a family foundation where it holds an interest in a foreign tax-transparent entity;

• excluding income from short-term rental from the tax exemption.

Contrary to earlier announcements, the public statements of the Ministry of Finance did not include information on a proposed amendment introducing the application of the solidarity levy to benefits paid to beneficiaries of family foundations.

According to the Ministry of Finance, the draft amendments to the Act on Family Foundations will be promptly submitted for public consultation. The proposed changes are expected to enter into force on 1 January 2026 and will apply to income of family foundations generated from that date.