Set up an SPF in Luxembourg: the family wealth-management company.
The SPF (family wealth-management company) is a Luxembourg vehicle dedicated to managing private wealth: it holds and manages financial assets for individuals or wealth structures. Exempt from direct taxes, it is subject to subscription tax and reserved for eligible investors, with no commercial activity. We incorporate it and keep it compliant.
The SPF is a Luxembourg capital company (SARL, SA, SCA…) governed by the law of 11 May 2007, whose exclusive purpose is the acquisition, holding, management and realisation of financial assets, excluding any commercial activity. It is exempt from corporate income tax, municipal business tax and net wealth tax, but subject to an annual subscription tax of 0.25%.
Law of 11 May 2007 on the family wealth-management company (SPF). Legal form governed by the amended law of 10 August 1915. Subscription tax of 0.25% (minimum EUR 100, maximum EUR 125,000 per year).
Key takeaway
- The SPF is reserved for managing private wealth: it holds financial assets, with no commercial activity.
- It is exempt from direct taxes (CIT, MBT, NWT) but subject to subscription tax of 0.25% (min EUR 100, max EUR 125,000/year).
- It is reserved for eligible investors (individuals, wealth entities, intermediaries acting on their behalf).
- The SPF does not benefit from tax treaties and cannot hold real estate directly or interfere in the management of its participations.
What is an SPF in Luxembourg?
The SPF (family wealth-management company) is a vehicle created by the law of 11 May 2007 to manage private wealth. Its purpose is exclusively the acquisition, holding, management and realisation of financial assets: shares, bonds, fund units, cash. It cannot carry on any commercial activity.
It is a tool of simplicity and tax neutrality to organise the holding of financial wealth, as opposed to the SOPARFI, which is active and treaty-eligible.
Who can own an SPF?
The SPF is reserved for eligible investors: individuals acting in the management of their private wealth, wealth entities acting exclusively for such persons (trusts, foundations, wealth companies), and intermediaries acting on their behalf.
Commercial companies and classic institutional investors are not eligible. We verify eligibility before incorporation and document compliance with this condition.
SPF taxation: exemption and subscription tax
The SPF is exempt from corporate income tax, municipal business tax and net wealth tax. In exchange, it is subject to an annual subscription tax of 0.25%, levied on paid-up capital, share premium and, where applicable, the portion of debt exceeding eight times the capital, with a minimum of EUR 100 and a maximum of EUR 125,000 per year.
The SPF does not benefit from Luxembourg tax treaties or the parent-subsidiary directive: foreign-source income may bear non-recoverable withholding tax. This often drives the choice between SPF and SOPARFI.
What an SPF cannot do
The SPF cannot carry on a commercial activity, hold real estate directly, interfere in the management of the companies it holds participations in, or grant interest-bearing loans as a business. Breaching these limits results in loss of the regime.
We set up compliance monitoring to preserve the SPF status and flag any risky operation.
SPF or SOPARFI: how to decide?
Choose the SPF to manage passive private financial wealth, with no need for tax treaties and no activity. Choose the SOPARFI to structure active investments, hold operational participations, benefit from treaties and the participation exemption, or carry on an ancillary activity.
We compare the two regimes against your assets, horizon and personal taxation before incorporating.
Who this is for
- Individuals and families organising the holding of financial assets
- Family offices structuring passive private wealth
- Investors wanting a simple, exempt vehicle
- Eligible wealth structures (trusts, foundations)
What we do
- Investor-eligibility and SPF-purpose verification
- Incorporation of the SPF (articles, notary, RCS, RBE)
- Accounting, annual accounts and subscription-tax monitoring
- Compliance with restrictions (no commercial activity)
- Advice on the SPF / SOPARFI trade-off by objective
Estimated timelines
Pricing indication
Indicative ranges, excluding disbursements and taxes. Firm quote after scoping.
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Preparation checklist
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The process, step by step
Eligibility & scoping
Verification of eligible investors and the nature of assets (financial). Confirmation that the SPF is the right vehicle rather than a SOPARFI.
Incorporation
Drafting articles compliant with the 2007 law, notarial deed, RCS registration and RBE entry.
Compliance
Monitoring set-up: exclusive purpose, eligibility attestation, subscription-tax filings.
Operation
LuxGAAP bookkeeping, annual accounts and day-to-day management, without crossing into commercial activity.
Frequently asked questions
What is an SPF in Luxembourg?
Who can invest in an SPF?
How is an SPF taxed?
Can an SPF hold real estate?
What is the difference between an SPF and a SOPARFI?
How much does it cost to set up an SPF?
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