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Luxembourg: Offshore Business Sectors

International Holding Companies

As from 2007, the replacement for the 1929 holding company is the Family Private Assets Management Company, or SPF. These new vehicles are prohibited from commercial activity, and are designed to be limited to private wealth management activity, for example the holding of financial instruments such as shares, bonds and other debt instruments, in addition to cash and other types of bankable asset. If the SPF is used to hold voting rights in other companies, it must ensure that it does not involve itself in the running of those companies, and it is prohibited from providing any kind of service.

The legal structure for an SPF requires that it is founded as a corporate entity such as corporation or limited liability entity and the company name must be suffixed by 'SPF'. Partners in an SPF can be trusts, private foundations, investor groups, familial groups or individuals.

From 2011, an SPF is subject to an annual flat income tax rate of EUR1,500 (increased to EUR3,000 from 2013).



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