A company formed under this provision may be limited by guarantee, or by both shares and guarantee. As such, it will have some of the features of both a partnership and a company. It is a particularly attractive vehicle in civil law jurisdictions which may not recognize the traditional common law trust concept. Civil law jurisdictions may view a transfer to a trust as no more than a transfer to an individual (with consequent gift or transfer tax implications) or as void ab initio, thus defeating the very purpose of the transfer. The hybrid company can effectively separate shareholder members from guarantor members and limit the rights of shareholders and guarantors so as to comply with the laws of the member´s domicile in the most tax-efficient way.