Philanthropy
Significant wealth carries a responsibility. For many of the families we advise, the question arises naturally: how can this wealth serve something beyond itself?
Structured philanthropy is not an act of spontaneous generosity. It is a wealth project in its own right, one that is planned, built and transmitted — exactly like an investment portfolio or a succession strategy. It addresses precise questions: what impact do you want to have? Over what time horizon? With what resources? Through which legal vehicle? With what governance? And how do you involve your heirs so that the commitment endures beyond your own lifetime?
At Belisama, we approach philanthropy without naïveté and without moralism. Our role is not to direct you, but to help you structure your commitment so that it is effective, tax-efficient, legally robust and transmissible to the next generations.
What we do
We operate across the entire philanthropic chain. Diagnosis first: understanding your motivations, identifying the causes that matter to you, assessing how much you wish to commit and over what horizon. Structuring next: selecting the right vehicle in the right jurisdiction — a Luxembourg foundation, a French fondation reconnue d’utilité publique, a fonds de dotation, a hosted foundation, a charitable trust under common law, or a temporary usufruct donation — each has its own advantages, constraints and tax treatment. We help you choose the one that fits your situation, your country of residence and your objectives.
Governance last: who decides how funds are allocated? How do you involve the next generation? How do you measure impact? How do you ensure the continuity of your commitment beyond your own lifetime? These are questions of family governance as much as philanthropy, and it is precisely here that our Family Office expertise is most valuable.
Why structure rather than give directly?
A direct gift is simple, but it is a one-off. It has no memory, no structure, no continuity. Structured philanthropy allows you to spread the effort over time, to optimise the tax treatment of the donation according to your country of residence, to create a family governance framework around shared values, and to build a legacy that transcends financial wealth.
The tax incentives vary significantly by jurisdiction. In France, donations to qualifying organisations benefit from a 66 % income tax reduction (capped at 20 % of taxable income) or a 75 % IFI reduction (capped at €50,000). In Luxembourg, donations to recognised public benefit organisations are deductible up to 20 % of taxable income or €1,000,000, whichever is lower. In Italy, donations to ONLUS and qualifying entities benefit from a 26 % tax credit (up to €30,000) or a deduction of up to 10 % of declared income. In the United Kingdom, Gift Aid allows charities to reclaim basic-rate tax on donations, while higher-rate taxpayers can claim additional relief. We map these incentives across jurisdictions to design the most efficient giving strategy for each family.
This is a subject that benefits from being addressed early, ideally in parallel with the succession strategy, and that gains enormously from close coordination between wealth planning, financial management and legal expertise.
Foundations and endowment vehicles
The choice of philanthropic vehicle is a structuring decision. It determines the tax treatment, the governance, the operational flexibility and the longevity of your commitment. Several families of vehicles coexist across European jurisdictions, each with its own characteristics.
The Luxembourg foundation
The Luxembourg patrimonial foundation is accessible without any condition of residence or nationality. It may pursue a public benefit purpose or a private patrimonial purpose, and benefits from a stable legal framework, competitive taxation and maximum flexibility. The foundation is governed by the amended law of 21 April 1928 and offers a high degree of control to the founder, who can reserve significant governance rights. It is particularly relevant for cross-border philanthropic projects or for multi-resident families wishing to centralise their philanthropic governance in a neutral jurisdiction with strong legal certainty.
The French fondation reconnue d’utilité publique (FRUP)
The most prestigious vehicle under French law for clients with French tax residence or significant French-source philanthropy. Full legal capacity, authorisation to receive donations and bequests, total exemption from transfer duties on gifts received. Its creation is demanding: review by the Conseil d’État, initial endowment generally exceeding €1.5 million, permanent administrative oversight. The FRUP is suited to major, long-term philanthropic commitments with high institutional visibility.
The French fonds de dotation
Created in 2008, this is the most flexible vehicle under French law. Simple declaration to the local prefecture, modest initial endowment (€15,000 minimum), light governance. Donors benefit from the same tax advantages as for a FRUP: 66 % income tax reduction up to 20 % of taxable income, or 75 % IFI reduction up to €50,000. Often the best entry point for structuring a philanthropic approach without a disproportionate administrative process.
The charitable trust (common law jurisdictions)
For families with ties to the United Kingdom, Ireland, or other common law jurisdictions, the charitable trust offers a well-established vehicle with significant tax advantages: exemption from income tax, capital gains tax and inheritance tax for qualifying trusts. The trust structure also provides flexibility in governance and in the allocation of funds across multiple beneficiary organisations. We coordinate the interaction between the charitable trust and the family’s continental European tax position to avoid double taxation and to maximise the aggregate philanthropic impact.
At Belisama, we help you choose the right vehicle by cross-referencing four criteria: the amount you wish to commit, your tax residence, the level of control you wish to retain, and the time horizon of your project. We then coordinate the implementation with all relevant parties.
Structured corporate philanthropy
Corporate philanthropy is not only for large corporations. For a business owner holding a patrimonial holding company or an operating entity, corporate philanthropy offers a direct tax lever. The tax treatment varies by jurisdiction: in France, a 60 % corporate tax reduction on donations up to €2 million (40 % above), capped at 0.5 % of turnover or €20,000. In Luxembourg, corporate donations are deductible under the same conditions as personal donations. In Italy, corporate donations to ONLUS benefit from a deduction of up to 10 % of declared income (Article 83 D.Lgs. 117/2017, Codice del Terzo Settore).
Corporate philanthropy is also a wealth structuring tool. Combined with a philanthropic holding — an intermediary structure that centralises flows and redistributes them according to a defined strategy — it allows the family to manage its philanthropic commitment with the same rigour as an investment portfolio: allocation by cause, impact tracking, annual reporting, shared governance with heirs.
For multi-resident families, we coordinate philanthropy across several jurisdictions — a complex exercise, but one that often allows the overall impact to be maximised while optimising the tax burden in each country.
Giving strategy
Giving is also about choosing when, how and through which mechanism. A well-designed giving strategy can transform a generous gesture into a powerful wealth planning act that reduces the tax burden, prepares the succession and involves the next generations.
Outright gift
The simplest and most direct mechanism. The donor irrevocably transfers an asset to a qualifying public-benefit organisation. The tax advantage is immediate, with the specific relief depending on the donor’s country of residence. This mechanism is suitable for straightforward portfolios or for significant one-off commitments.
Temporary usufruct donation
A little-known but extremely powerful tool, available under both French and Luxembourg law. The donor transfers the usufruct of an asset (rental property, securities portfolio) to a public-benefit organisation for a defined period. During this period, the organisation receives the income and the asset is removed from the donor’s wealth tax base. At maturity, full ownership automatically reverts to the donor. It is an ideal lever for heavily taxed portfolios wishing to support a cause without permanently relinquishing their assets.
Post-succession donation
In France, heirs may, within twelve months of death, donate all or part of the assets received to a qualifying public-benefit organisation (Article 794 CGI). This donation gives rise to an uncapped deduction from the heir’s net succession share. In Italy, a similar mechanism exists through donations to ONLUS within the succession framework, benefiting from the favourable inheritance tax regime (4 % above €1 million in direct line). We integrate these mechanisms systematically into succession planning, particularly for large estates or indirect-line successions where marginal tax rates are highest.
We help our clients build a multi-year giving strategy, calibrated to their contributive capacity and integrated with their overall wealth strategy. The objective is not to maximise the tax deduction, but to maximise impact while preserving the coherence of the estate.
