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holding, acquisition, management and realization of financial assets such as shares, bonds, securitization funds, term accounts, SICAV...
in addition, the SPF is authorized to issue securities and to borrow from its shareholders or third parties.
Prohibited activities
the exercise of any commercial activity.
ownership of real estate by the SPF, either directly or indirectly through other companies.
the granting of interest-bearing loans to third parties or even to companies in which the SPF holds a stake (in the latter case, however, loans on an ancillary basis and free of charge are permitted).
SPF shareholders
Individuals, whether resident or non-resident.
SPF shareholders may also be “patrimonial” entities, whether resident or non-resident, acting in the context of private wealth management.
- Control of the SPF by the Registration and Domains Administration
- Tax treatment of SPFs
Taxes related to its incorporation
Capital duty/ abolished on January 1, 2009
Subscription tax: the tax base is made up of the paid-up capital, debts and share premium. The tax is payable quarterly. The annual rate is 0.25%, with a minimum of 100 euros and a maximum of 125,000 euros.
- Tax on income and dividends, profits or any other income received by the SPF.
- Taxation on capital gains realized on the sale of SPF shares: this depends on the shareholder's status:
If the shareholder is a Luxembourg resident, he or she will be subject to tax.
If they are not, they will be exempt.
Tax treatment of the SPF
Wealth tax: the SPF is not subject to wealth tax.
Value-added tax: the SPF is not subject to VAT.
The SPF does not benefit from double taxation treaties or EU directives (Directive 90/435/EEC).
Tax treatment of income received from the SPF
Wealth tax: the SPF is not subject to wealth tax.
- Luxembourg resident shareholders: no withholding tax, but subject to local personal income tax (tax charge 30.38% from € 15,000).
- Non-Luxembourg resident shareholders: no withholding tax.
Taxation of SPF income will be the exclusive responsibility of their state of residence.
On interest paid on SPF advances and debts to individuals:
- Shareholders resident in Luxembourg: withholding tax of 10%.
- Non-resident shareholders: withholding tax of 15%.
Subscription tax: the tax base is made up of paid-up capital, debts and share premium. The tax is payable quarterly. The annual rate is 0.25%, with a minimum of 100 euros and a maximum of 125,000 euros.
- Tax on income and dividends, profits or any other income received by the SPF.
- Tax on capital gains realized on the sale of SPF shares: this will depend osn the status of the shareholder:
