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Family Estate Management Company (SPF)

Family Estate Management Company SPF and Luxembourg buildingsThe Luxembourg Family Estate Management Company, SPF, was created by the Law of 11 May 2007; it is intended solely for:
private individuals managing their private assets;
- an estate entity acting solely in the interest of the private assets of one or more private individuals;

- an intermediary acting on behalf of investors meeting the aforementioned criteria.
Its sole business purpose is the acquisition, ownership, management and liquidation of various financial assets. It bears mentioning that, despite the use of the word “family”, there is no kinship requirement between the various shareholders of the SPF.

In legal terms, the SPF may be an SA, an SARL, a company limited by shares (société en commandite par actions, SCA), or a cooperative company organised as an SA (Société Coopérative organisée sous forme de Société Anonyme).
Shares of a SPF may not be listed on any stock market. The SPF may not directly own any property.
The SPF may hold stakes in another company, provided it does not interfere in the management of said company.

SPF is exempt from income tax, communal trade tax, and wealth tax

The SPF is excluded from international tax treaties.

Fiscally, the SPF is exempt from income tax, communal trade tax, and wealth tax. However, it is subject to an annual 0.25% subscription tax calculated on the basis of its paid-up capital plus any applicable premium on shares, and on that part of its debt which exceeds eight times its paid-up capital plus any premium on shares. It bears mentioning that the amount of the subscription fee may not be less than 100 EUR, nor more than 125,000 EUR.
In conclusion, it appears that, because of its flexibility and almost complete exemption from taxes, the SPF is the ideal vehicle for any private individual seeking both a tax optimisation of his current assets and an ideal estate-transfer planning.

Interested in creating a Luxembourg Family Estate Management Company, SPF? Contact us for further information.


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Abroad fiduciaire is a member of the Order of Chartered Accountants of Luxembourg