The new SPF regime, adopted by the Parliament on may 11, 2007, follows the main patterns of the previous H29 regime but has a slightly different scope of application. It can be regarded as a more than suitable alternative for private wealth and asset management purposes.

The law of may 11th 2007 limits the object of a SPF to the acquisition, holding and management of financial assets, as defined by the law, excluding any business activity. A SPF can hold participations in companies, provided it is not involved in the management of these companies. The SPF having to remain a passive investor, it may not provide remunerated services to any of its participations.

A SPF is exempt from both corporate income tax and net worth tax in Luxembourg; also divided payments made by a SPF to its shareholders will be exempt from withholding tax.

Capital gains generated by the sale of shares of a SPF by non-resident shareholder won't be taxable in Luxembourg.

More information upon request.

A SOPARFI main business purpose is the holding of participations in domestic and foreign companies, but can be used for other activities (also commercial). Soparfis benefit better from E.U.-wide participation exemption laws and from double-tax treaties, with respect to the treatment of dividends and capital gains from participations.

A Luxembourg Soparfi can be used as either an intermediate finance company, a holding company or as a combination of both.
It can also be used as an ultimate holding company of, for example, a European group, thus providing an advantageous exit-scenario as the liquidation distributions by a Soparfi are not subject to Luxembourg withholding taxes.

Furthermore, in certain cases, a Soparfi can act as an intermediate royalty company and operate as a head office of foreign branches.

More information upon request.