Holdings, SOPARFI & wealth in Luxembourg
Structuring participation holding and private wealth: SOPARFI, SPF, holding, family office.
This hub serves investors and families holding participations or wealth through Luxembourg. It covers the SOPARFI and SPF, participation exemption, strategic, acquisition and real estate structuring, plus family office and succession.
What is a SOPARFI and an SPF in Luxembourg?
The SOPARFI is a fully taxable Luxembourg company whose purpose is holding and financing participations; subject to conditions, it benefits from the exemption of dividends and capital gains (participation exemption). The SPF is a private wealth-management vehicle reserved for individuals, with no commercial activity.
The choice between SOPARFI and SPF depends on the assets and the objective: active holding and tax treaties for the SOPARFI, passive wealth management for the SPF.
Structuring participation holding and private wealth
This hub structures participation holding and private wealth: holding, strategic, acquisition and real estate structuring, family office, succession and private banking. Each structure is scoped to your tax position, co-investors and horizon.
Substance and compliance: securing your holding
A Luxembourg holding is only effective if its substance is real: office, governance, accounting and decisions taken in Luxembourg. We ensure ATAD substance, accounting and compliance, for a structure defensible before authorities and banks.
Services in this hub
SOPARFI
Fully taxable holding, art. 166 LIR
SPF
Private wealth management company
Holding company
Participation holding structure
SOPARFI vs SPF
Holding vehicles compared
SOPARFI taxation
Tax regime, withholding, NWT
Participation exemption
Art. 166 LIR: dividends, capital gains
Strategic structuring
Vehicle selection, substance, compliance
SOPARFI structuring
Ownership, flows, participation exemption
Holding structuring
Ownership, financing, protection
Acquisition structuring
M&A vehicle, financing, exit
Real estate structuring
PropCo/HoldCo, real estate fund
Private wealth structuring
SPF, holding, wealth reporting
Family office
Administration, consolidated reporting, coordination
Succession & transfer
Structuring, gifting, notary coordination
Private banking
Structuring then introduction
Investor immigration
Residence permits, relocation
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