The May 11, 2007 Act provides, inter alia, the purpose of the Société de gestion de Patrimoine Familial (SPF) as follows:
“The acquisition, holding, management and realisation of financial assets excluding any commercial business.”
The future SPF is designed as an investment company solely intended for individuals acting in the framework of the management of their private assets. Shareholders should be individuals (restricted circle of investors, family group…) or entirely referred to as asset companies (trust, private foundations).
Fiscally, the future SPF should benefit by:
- a contribution right limited to 1% with exemption possibility, upon incorporation
- an annual subscription tax of 0.25% per year only
- a wealth tax exemption (I.F.) • I.R.C. and I.C.C. tax exemptions
- source withholding exemption for dividends paid to shareholders of the SPF. (The latter are taxed in their country of residence)
- taxation limited to 10% for Luxembourg residents and 15% for non-residents in Luxembourg on interest paid by the SPF to individuals
- no debt ratio.
However, that SPF company would not benefit by double taxation agreements signed by the Grand-Duchy. The SPF should be exempted from an establishment permit.
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