SPF Holding

SPF, A Family PRIVATE ASSET Management company

Regulations on SPF companies have kept some advantages of the Holding 29, and have taken into consideration the comments of the European Commission leading to the disappearance of these companies (31/12/2010).

SPF definition

SPF means “Société de gestion de Patrimoine Familial” (Family Private Asset Management Company).

The SPF is intended to acquire, hold, realize and manage financial assets in the same manner as an individual could do. It is an ideal holding company to hold bonds, quoted shares, financial products in general.

It cannot hold directly real estate, but shares of subsidiaries (real estate companies, holding companies, trading companies...).

So it is a wealth management company but not a direct real estate property management company.

It cannot perform any commercial activity, investment management, neither grant remunerated loans.

The company is a joint-stock company, mainly a public limited company or a limited liability corporation.

Tax system

From a tax point of view, a SPF:

• is not liable for income or capital gain taxes. It is a tax exempt company.

• is not subject to tax conventions nor to the parent-subsidiary European Directive, consequently a withholding tax applies to dividends distributed by its subsidiaries in the country where they are located,

• is not liable to a withholding tax on dividends distributed to his(their) shareholder(s),

• is not liable to any tax on earnings, but to a subscription tax representing an estimated income of 0.25% of the paid-up share capital.

It is interesting to change a Holding 29 into a SPF when it holds financial assets, to remain enjoying the advantages of Luxembourg.