SPF Table

Practical useIndividuals wishing to optimize their
personal tax planning (private wealth management purposes).
Applicable legislationLaw of 11 May 2007 (“SPF Law”)
Eligible investorsRestricted to:
- natural persons acting in the context of the management of their personal wealth;
- management entities acting solely in the interest of the private wealth (e.g. trusts, private foundations); and
- intermediaries acting for the
account of the above mentioned eligible investors (e.g. bank acting under a fiduciary agreement).
Eligible assetsRestricted to acquisition, detention, management and realization of financial assets.
The SPF is not allowed to carry out commercial activities or to hold directly real estate (except for its own use or through its participations).
Risk diversification requirementsNo risk diversification requirements.
Legal Form- SA
- Sàrl
Segregated compartmentsNo
Capital requirementsDepends of the form:
- SA / SCA: EUR 31,000
- Sàrl: EUR 12,500
- SCoSA: no minimum capital
Net asset value (NAV) calculation and redemption policyNot required.
Corporate income taxNo corporate income tax
Subscription taxAnnual subscription tax of 0.25% on
the amount of paid up capital and
issue premium (if any).
Wealth taxNo wealth tax.
Withholding tax on dividends / interests and capital gainsNot subject to withholding tax except
if EU Savings Directive applies.
Benefit from double tax treaty networkNo
Benefit from the EU Parent Subsidiary DirectiveNo
Authorisation and supervision by the CSSFNo
Possibility of listingNo
European passportNo
Thin capitalization rules (debt-to-equity ratio)Tax of 0.25% on the debt that exceeds 8 times the paid-up capital increased by the issue premium.
Required Luxembourg service providersNo