Insights · Family wealth

Luxembourg SPF: the family wealth company, its tax and its limits in 2026

The SPF is Luxembourg's vehicle for private portfolios: no corporate tax, no withholding on payouts, 0.25% a year. It also has strict limits and, since 2025, real penalties. Everything you need to decide, plus a calculator.
Calculate your SPF tax ↓

Reading time7 minutes
TopicSPF
Rules as ofOctober 2026
AuthorAlexander Baranov
The short version

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.

01 · The basics

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.

Tax

0.25% a year

Subscription tax only. No corporate tax, no municipal tax, no net wealth tax.

Payouts

0% withholding

Dividends and liquidation proceeds leave Luxembourg free of withholding tax.

Investors

Families only

Individuals and the entities acting for them; no institutions.

Assets

Financial only

Shares, bonds, funds, cash; no direct real estate, no business.

02 · Tax

How the SPF is taxed in 2026

Item2026
Corporate income tax and municipal business taxExempt
Net wealth taxExempt
Subscription tax0.25% of paid-up capital and share premium, plus debts above 8 times that amount
Minimum and maximumEUR 1,000 minimum (since 2025), EUR 125,000 maximum per year
Withholding on dividends paidNone
Treaties and EU directivesNot available
ShareholdersTaxed 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.
03 · The rules

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.
04 · New rules

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.
Thinking of an SPF, or need yours checked against the 2025 rules?We set up SPFs, run their compliance and annual certificate, and convert them to SOPARFIs when the family's needs change.
Book a free call
05 · Comparison

SPF vs SOPARFI: which one do you need?

SPFSOPARFI
Best forPassive portfolio of listed securities and fundsHolding operating companies, real estate, group financing
Corporate taxNoneAbout 23.87% in Luxembourg City, with participation exemption
Annual tax0.25% subscription taxNet wealth tax of 0.5%, with an annual minimum
Treaties and directivesNoYes
Foreign dividendsWithholding usually finalOften 0% under the directive or reduced by treaty
Can manage subsidiariesNoYes
Substance expectedLightBoard, decisions and records in Luxembourg
06 · Your SPF

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.

Who will hold the shares?
What will it hold?
Will it receive dividends from abroad that suffer withholding?
010.25%, capped

EUR 1,000 to EUR 125,000 a year, nothing else in Luxembourg.

02Financial assets only

No business, no direct property, no managed subsidiaries.

03No treaties

Foreign withholding tax usually stays a cost.

042025 rules

Annual certificate, SPF in the name, real fines.

07 · FAQ

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.

Your structure

Setting up or reviewing an SPF?

We set up SPFs and SOPARFIs, handle the annual certificate and filings, and tell you honestly when an SPF is the wrong tool.