There is to be a surcharge on undistributed trading profits. A company incorporated in Ireland is to be treated as resident. This rule affords a limited opportunity for a treaty partner resident to work in Ireland without paying tax either in Ireland or in his country of residence. Irish residents are affected by general anti-avoidance legislation, exit charges on companies and trusts and apportionment of capital gains of offshore companies. The Stichting is a legal entity with corporate status, not essentially different from the Danish Foundation.
Gift tax is payable on the funds donated to the Stichting by a Dutch-resident donor.
A foundation can function as the parent of a group or as a subsidiary. Third parties may benefit from contractual arrangements with the foundation, but distributions must be of an ideological or social nature. A foundation which merely holds assets is not liable to corporation tax. The co-operative association must have at least one Dutch member. It may distribute profits without withholding tax and may enjoy the participation privilege.