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.
For asset portfolios and specialised financing, distinguish a holding company from Luxembourg securitisation vehicles, which have distinct accounting and risk requirements.
Which vehicle for which objective?
Holding and financing subsidiaries: the SOPARFI, fully taxable, qualifies for the participation exemption subject to conditions. Managing private wealth with no commercial activity: the SPF, reserved for individuals. Undecided between the two: the SOPARFI or SPF comparison settles it criterion by criterion.
You first want to understand how a Luxembourg holding company works before choosing. You are preparing a buyout: acquisition structuring. You are organising family wealth: the family office.
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 defended by real substance: office, governance, accounting and decisions taken in Luxembourg. We ensure economic substance (ATAD), accounting and compliance, for a structure defensible before authorities and banks.
Services in this hub
SOPARFI
Definition, uses, set-up
SPF
Private wealth management company
Holding company
Category, uses, vehicles
SOPARFI vs SPF
Holding vehicles compared
SOPARFI taxation
Taxation, withholding, net wealth tax
Participation exemption
Art. 166 LIR: dividends, capital gains
Choosing a structure
SOPARFI, SPF, SCSp, SARL, RAIF: comparison
Acquisition structuring
M&A vehicle, financing, exit
Real estate structuring
PropCo/HoldCo, real estate fund
Family office
Administration, consolidated reporting, coordination
Succession & transfer
Structuring, gifting, notary coordination
Private banking
Structuring then introduction
Investor immigration
Residence permits, relocation
A project around “holdings, soparfi & wealth”?
First reply within 24 working hours, from a named adviser. Firm quote within 48 working hours once the scope is defined. NDA on request before any confidential document.
Frequently asked questions
SOPARFI or SPF: which to choose?
The SOPARFI suits active holding of participations with tax-treaty access; the SPF, reserved for individuals, suits passive wealth management with no commercial activity.
What is the participation exemption?
It is the regime that exempts, subject to threshold and holding-period conditions, the dividends and capital gains a SOPARFI receives from its qualifying subsidiaries.
Does a holding need substance?
Substance requirements depend on the holding's functions, transactions and tax position. Real substance (office, governance, accounting, local decisions) matters most where the participation exemption or treaty benefits are relied upon against anti-abuse rules.