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In cases where a Greek-connected family holds an operating business, investment assets and property in more than one country, the discussion may quickly turn to whether those interests should be placed in a trust, foundation or Anstalt. The founder may wish to preserve concentrated ownership, provide for family members living in different jurisdictions and establish a framework through which authority can pass without fragmenting the assets.
The question is often framed as a choice between legal vehicles. In reality, it is a choice between different models of ownership, governance and succession, each of which must be assessed alongside the family’s Greek legal and economic connections.
Similar objectives do not make the structures interchangeable
Liechtenstein law provides a useful illustration of the distinctions.
A foundation consists of independent assets constituted as a legal person for a defined purpose, with the founder determining its assets, purpose and beneficiaries. A trust has no separate legal personality, with the trustee administering the transferred property in its own name as independent legal owner for the beneficiaries. An Anstalt is a legally autonomous undertaking with its own assets and legal personality.
Those differences affect how the assets are owned, who exercises authority and how the founder’s intentions are carried forward. They also shape the respective roles of trustees, foundation councils, beneficiaries and other officeholders.
The family’s purpose should guide the choice
A structure intended to preserve a Greek family business may require a different governance model from one holding a diversified investment portfolio. Property in several countries may raise local questions of ownership, financing and recognition, while beneficiaries living abroad may introduce different succession and tax considerations.
The founder’s intended role is equally important. A family seeking meaningful separation between the founder and the assets may require a different arrangement from one in which defined powers are to be retained during the founder’s lifetime. The choice must also account for how authority should pass and whether later generations should participate directly in governance.
Greek consequences remain relevant even where the structure is constituted abroad. The Greek tax authority has issued specific guidance on the treatment of foreign trusts and foundations, confirming that these vehicles may carry domestic consequences for Greek-connected founders and beneficiaries.
Where the choice tends to weaken
Difficulty often arises when the vehicle is selected before the family has agreed what it must accomplish. A foundation may be chosen for its legal personality without sufficient attention being given to the composition and succession of its governing body. A trust may be established without a settled view of the discretion expected of the trustee. An Anstalt may offer useful flexibility while leaving unresolved how its powers will operate after the founder steps back.
The same weakness appears where the foreign structure is considered in isolation from Greek assets, succession rights, tax residence and the wider estate. A vehicle may be entirely coherent under Liechtenstein law while producing consequences elsewhere that were never incorporated into the original design.
The choice between a trust, foundation and Anstalt should therefore begin with the family rather than the form. The appropriate structure is the one capable of carrying its particular combination of assets, authority and purpose across every jurisdiction in which it must operate.