Like a TMK structure, these distributions can be deducted from GK`s revenues under the TK agreement as deductions (as defined in the rules published by the NTA). In order to benefit from this treatment, the TK agreement should stipulate that the role of investors is limited to passive investments. In practice, it is customary for the management of the GK operator to be outsourced or handled by an investor subsidiary. While profit distributions (dividends) may be considered deductions on business income, these distributions remain subject to withholding tax of 20.42%, subject to reductions in the current double taxation agreements. In summary, GK-TK offers advantages very similar to a TMK: the company itself has no legal personality. All assets of the partnership are owned by the manager; However, anonymous partners are entitled to a share of the company`s profits, as stipulated in the partnership agreement. Anonymous partners are only limitedly responsible for the company`s debt, provided they are anonymous. If an anonymous partner authorizes the use of its name in the manager`s name or in the name of the partnership, the anonymous partner loses its limited liability.  A tokumei-kumiai (TK) is a form of partnership based on an agreement between a thought partner (i.e. investors) (i.e. TK partners) or tokumei-kumiai-in) and a GK (as a TK or eigyosha operator).
As part of a GK-TK structure, a GK is created as a destination vehicle, whose sole purpose is usually to hold assets (e.g.B. shares in toll real estate or TBI). The process of bundling a GK is simple as described above. The TK agreement can be signed by TK partners and a GK at any time, but only after the creation of GK. The TK agreement is not submitted or made available to the public. In accordance with TK`s agreement, the investor makes funds available to GK to force GK to distribute a portion of the profits from GK`s activities. The role of the investor is limited to that of a passive investor with contractual rights under the TK agreement. The liability of the TK investor is therefore limited and investors are not held responsible for obligations arising from GK`s activities that exceed the amount of their respective contributions.
Direct acquisition of real estate assets by foreign investors as opposed to EU citizens (individuals or legal entities) is reciprocal (i.e. it is permissible to acquire real estate in the investor`s country of origin) and subject to the written agreement of the Ministry of Justice.