A Luxembourg SPF pays only a 0.25% annual subscription tax, between EUR 1,000 and EUR 125,000, and nothing on dividends it pays out. In exchange it may hold only financial assets, may not manage its holdings or own real estate directly, accepts only private investors and has no treaty access. It is ideal for a passive portfolio and wrong for operating companies, which belong in a SOPARFI.
What a Luxembourg SPF is, in one minute
The SPF, société de gestion de patrimoine familial or family wealth management company, is Luxembourg's vehicle for private investment portfolios. It was created in 2007 to replace the 1929 holding company, and it remains the closest thing Luxembourg has to a tax-neutral personal investment company.
0.25% a year
Subscription tax only. No corporate tax, no municipal tax, no net wealth tax.
0% withholding
Dividends and liquidation proceeds leave Luxembourg free of withholding tax.
Families only
Individuals and the entities acting for them; no institutions.
Financial only
Shares, bonds, funds, cash; no direct real estate, no business.
How the SPF is taxed in 2026
| Item | 2026 |
|---|---|
| Corporate income tax and municipal business tax | Exempt |
| Net wealth tax | Exempt |
| Subscription tax | 0.25% of paid-up capital and share premium, plus debts above 8 times that amount |
| Minimum and maximum | EUR 1,000 minimum (since 2025), EUR 125,000 maximum per year |
| Withholding on dividends paid | None |
| Treaties and EU directives | Not available |
| Shareholders | Taxed in their country of residence; non-residents pay no Luxembourg tax on SPF dividends |
An SPF holding EUR 10 million of listed funds pays EUR 25,000 a year in Luxembourg tax, whatever the portfolio earns.
What an SPF may and may not do
- Hold financial assets. Shares, bonds, units in funds, cash, derivatives and other financial instruments, including shares in companies it does not manage.
- No commercial activity. It may not trade, provide services or run a business, directly or through partnerships.
- No management of subsidiaries. It may hold participations but may not interfere in their management.
- No direct real estate. Shares in property companies are fine; buildings in its own name are not.
- No interest-bearing loans to its holdings. Loans to companies it holds a stake in must not pay interest.
- Private investors only. Shares cannot be offered to the public or listed.
What changed in 2025
- Name. The company name must include “SPF” or “société de gestion de patrimoine familial”.
- Annual certificate. A compliance certificate confirming the SPF meets its legal conditions must be filed each year.
- Minimum tax. The minimum subscription tax rose to EUR 1,000.
- Sanctions. Fines up to EUR 250,000 for serious breaches, and loss of SPF status if the breach is not fixed within six months.
SPF vs SOPARFI: which one do you need?
| SPF | SOPARFI | |
|---|---|---|
| Best for | Passive portfolio of listed securities and funds | Holding operating companies, real estate, group financing |
| Corporate tax | None | About 23.87% in Luxembourg City, with participation exemption |
| Annual tax | 0.25% subscription tax | Net wealth tax of 0.5%, with an annual minimum |
| Treaties and directives | No | Yes |
| Foreign dividends | Withholding usually final | Often 0% under the directive or reduced by treaty |
| Can manage subsidiaries | No | Yes |
| Substance expected | Light | Board, decisions and records in Luxembourg |
Calculate your subscription tax and check eligibility
Two numbers and three questions. The result updates as you type.
SPF calculator and eligibility check
Enter your figures and tick what the SPF will hold. You get the annual subscription tax and any red flags.
EUR 1,000 to EUR 125,000 a year, nothing else in Luxembourg.
No business, no direct property, no managed subsidiaries.
Foreign withholding tax usually stays a cost.
Annual certificate, SPF in the name, real fines.
Luxembourg SPF: frequent questions
What is a Luxembourg SPF?
The SPF (société de gestion de patrimoine familial) is a Luxembourg company created by the law of 11 May 2007 to hold and manage the private financial wealth of individuals. It pays no corporate income tax, municipal business tax or net wealth tax, only an annual subscription tax of 0.25%.
How much tax does an SPF pay?
An annual subscription tax of 0.25% on paid-up capital and share premium, plus the part of its debts above eight times that amount. Since 2025 the minimum is EUR 1,000 and the maximum stays at EUR 125,000 a year.
Can an SPF own real estate?
Not directly and not through transparent vehicles. It can hold shares in property companies, as long as it does not take part in their management.
Can an SPF use tax treaties?
No. The SPF is excluded from the EU parent-subsidiary directive and generally from Luxembourg's tax treaties, so foreign withholding tax on its income is usually a final cost.
SPF or SOPARFI?
An SPF suits a passive portfolio of listed securities and funds. A SOPARFI suits holdings of operating companies, intra-group loans, real estate and anything needing treaty or directive access.
Who can invest in an SPF?
Only individuals managing their private wealth, and entities acting exclusively for them such as family offices, trusts or foundations. Institutional investors are not allowed.