WEALTH, 02Aut. 10077274 · 142 Boulevard de la Pétrusse, Luxembourg

Private wealth structuring in Luxembourg, SPF, holding and wealth reporting.

Wealth structuring organises the ownership of an individual's or family's assets through the right Luxembourg vehicles (SPF, holding, SOPARFI). FSL handles set-up, administration and reporting. FSL handles structuring, administration and reporting; wills, gifts and notarial deeds are coordinated with our network of partner notaries and lawyers.

In short

Private wealth structuring in Luxembourg organises the ownership of a private estate through suitable vehicles (SPF for passive financial assets, holding/SOPARFI for participations), to optimise governance, clarity and transfer.

Legal basis

Law of 11 May 2007 on the family wealth management company (SPF); participation exemption art. 166 LIR for SOPARFIs. The SPF is exempt from income tax but subject to subscription tax and excluded from tax treaties.

Key takeaway

  • SPF for passive private financial wealth; SOPARFI/holding for active participations.
  • An SPF cannot carry on commercial activity or hold real estate directly.
  • FSL structures and administers; notarial acts and legal opinions are coordinated.

Who this is for

  • Wealthy individuals and families
  • Entrepreneurs reorganising wealth after an exit
  • Resident and non-resident international investors

What we do

  • Scoping: SPF vs holding/SOPARFI depending on assets
  • Incorporation, accounting and substance of vehicles
  • Consolidated wealth reporting
  • Coordination with legal and tax advisers

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Preparation checklist

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FAQ

Frequently asked questions

SPF or SOPARFI for my wealth?
The SPF suits passive ownership of financial assets by eligible investors, with no commercial activity. The SOPARFI suits active participations and benefits from treaties and the participation exemption (art. 166 LIR).
Can an SPF hold real estate?
Not directly. The SPF cannot hold property directly; a dedicated structure (often a SOPARFI) is used for real estate.
Is the SPF taxed?
It is exempt from income tax but subject to a subscription tax and excluded from tax-treaty benefits. Investor eligibility is regulated.
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