Mickaël LOC/SPF LuxembourgFRENDE
SPF · family wealth · Luxembourg

An SPF has to be governed, not only incorporated.

The family wealth management company looks simple and is demanding over time: its perimeter is strictly bounded and loss of status is a governance risk before it is a tax risk. I check eligibility, coordinate the set-up with the notary and the tax adviser, then run the structure: registers, accounting, filings and a resident manager.

✓Establishment authorisation 10077275, verify on the official register

Direct answer
The SPF, governed by the amended law of 11 May 2007, is a capital company reserved for individuals managing their private wealth. Its activity is strictly bounded, it bears a 0.25% subscription tax, and loss of status is prevented continuously through governance.
Key facts
Legal framework
Amended law of 11 May 2007 on the creation of a family wealth management company
Eligibility
Individuals acting within the management of their private wealth
Subscription tax
0.25%, annual floor of EUR 1,000, ceiling of EUR 125,000, quarterly declaration and payment
Prohibitions
No commercial activity, no direct acquisition of property, no remunerated loan, no interference in the management of the companies held
Property
Can be held only through capital companies
Public reference
Establishment authorisation No. 10077275, nine activities, verifiable on Guichet.lu
Last verified
3 October 2026

Who an SPF is for, and who it is not for

An SPF suits an individual, or a family organised around one, who holds private financial wealth and wants to group it in a readable Luxembourg vehicle. It does not suit an entrepreneur who would house an activity in it, nor a structure whose operations would be financed by third parties.

  • Suitable: securities portfolio, shareholdings held privately, cash, family grouping of these assets.
  • Not suitable: commercial activity, invoiced services, direct acquisition of property, remunerated loans, involvement in the management of the companies held.
  • To be weighed: when the assets are shareholdings in operating companies, a SOPARFI may fit better. The structuring page compares the two.

Four points where an SPF becomes fragile

An activity that drifts

A remunerated loan to a shareholding, an invoiced service, a management decision taken in a company held: each can take the structure out of its perimeter.

Exposure: status
Property acquired directly

An SPF cannot acquire property directly. Property is held through capital companies, which is decided before the acquisition.

Exposure: status
Absent management

Without a manager who is actually present, substance and the place of effective management can be challenged, and the bank asks questions with no answer.

Exposure: substance
A forgotten calendar

Quarterly declaration and payment of subscription tax, annual accounts, RCS filings and RBE updates: a delay costs more than the service that would have avoided it.

Exposure: compliance

Three engagements

01 · Eligibility

Eligibility review

Individuals considering an SPF, or holding one and wanting it re-read.
  • Nature of assets and flows, one by one
  • Prohibitions: activity, property, loans, interference
  • Comparison with a SOPARFI depending on the assets
  • Written note: decision, risks, timetable
Fixed feeQuoted after a first reading of the file.
02 · Set-up

SPF set-up

Families that have decided to incorporate or take over an SPF.
  • Project management with the notary and the tax adviser
  • Capital circuit, RCS, RBE, bank file
  • Registers and first resolutions
  • Annual calendar of obligations
Set-up feeSet in writing before work starts.
Most requested
03 · Governance

Governance and annual monitoring

Existing SPFs that need resident management and documentary discipline.
  • Gérant or administrateur mandate held in my own name
  • Accounting, annual accounts, subscription tax
  • Continuous monitoring of the authorised perimeter
  • Annual governance review
Annual feeQuoted after reviewing the file. No success fee on a corporate mandate.

What my authorisations cover, and what stays outside

Step
What is delivered
Basis
Management of the formation project
coveredCoordination with the notary, capital circuit, RCS, RBE, bank onboarding file.
Authorisation 10077275 / 3 · auxiliary commercial services
Accounting and filings
coveredBookkeeping, annual accounts in eCDF format, subscription tax follow-up, calendar.
Authorisation 10077275 / 0 · accountant (comptable)
Corporate secretarial and substance
coveredRegisters, board meetings, resolutions, premises with auxiliary services and substance file.
Authorisations 10077275 / 3 and / 4
Manager of the SPF
coveredGérant or administrateur mandate held in my own name, with conflict-of-interest review.
Authorisation 10077275, corporate mandates
Drafting of articles and deeds
outsideNotary or lawyer registered at the bar.
Separate regulated professions
Tax opinion, choice of investments
outsideBinding tax opinion: tax adviser. Selection of financial instruments, investment advice, portfolio management: financial-sector activities, not carried out here.
Amended law of 5 April 1993

What I do not accept

  • SPFs whose beneficial owner cannot be documented to a normal anti-money-laundering standard.
  • Structures whose real purpose is a commercial activity.
  • Manager mandates with no real role in the decision.
  • Any advice on the choice of investments of the wealth held.

How an engagement starts

Step 01
Mutual NDA

Signed before any name, structure or family member is discussed.

same day
Step 02
File review

Identity of beneficial owners, assets, flows, existing articles.

indicative: 5 to 10 working days
Step 03
Written note

Eligibility, risks, proposed scope of engagement, fees.

indicative: 2 to 3 weeks
Step 04
Engagement

Scope, deliverables, timetable, fees and exclusions fixed in writing.

before any start

Start with the NDA

Document · Mutual NDA · Luxembourg law
Confidentiality agreement, corporate engagements and directorships
To be signed before any name, structure or counterparty is discussed. Readable online, or downloadable as a PDF to return signed.
Draft subject to legal validation. The NDA is a structured template, not legal advice. Its scope and wording must be validated by a Luxembourg legal professional before use.

Intents covered by this page

IntentSPF LuxembourgEligibility, prohibitions, subscription tax.IntentFamily wealth management companyLaw of 11 May 2007, perimeter, governance.IntentSPF or SOPARFIChoosing by assets and exit.Structuring page →IntentFamily transmissionGovernance between generations.Transmission page →

Authorisation certificates to download

Each certificate is the official document issued by the Ministry of the Economy, with its QR code. Scan the QR code with the GouvCheck app, which checks the authenticity and currency of the document.

GouvCheck QR code of authorisation 10077275 / 0
10077275 / 0
Accountant (comptable)
Issued 25/03/2025
Download PDF ↓
GouvCheck QR code of authorisation 10077275 / 3
10077275 / 3
Auxiliary commercial activities and services
Issued 25/03/2025
Download PDF ↓
GouvCheck QR code of authorisation 10077275 / 4
10077275 / 4
Shared workspace and offices with auxiliary services
Issued 16/04/2025
Download PDF ↓

The authorisation is personal and revocable. Public verification: official Guichet.lu register.

Evidence and verification

Every statement on this page that can be verified independently is listed below with its source. Items that cannot yet be verified are flagged and are not presented as facts.

Claim
Evidence
Source
Establishment authorisation 10077275
verifiableNine activities, issued by the Ministry of the Economy
Public register Guichet.lu
SPF regime
verifiableIndividuals, bounded activity, subscription tax 0.25%
Amended law of 11 May 2007
Financial-sector activities not carried out
verifiableNone of the nine authorisations covers investment advice or portfolio management
Amended law of 5 April 1993
Mandate capacity
declaredDeliberately limited, availability communicated when the file is opened
Statement by the holder

This page follows the site's editorial policy: a statement is either sourced or flagged. Corrections follow the corrections policy. The content is general information, not legal or tax advice.

Frequently asked questions

What is an SPF in Luxembourg?
The family wealth management company is a capital company governed by the amended law of 11 May 2007, reserved for individuals managing their private wealth. Its activity is strictly bounded and it bears an annual subscription tax instead of corporate income tax.
What are the prohibitions of an SPF?
No commercial activity, no direct acquisition of property, no remunerated loan, even to a shareholding, and no interference in the management of the companies held. These prohibitions are monitored continuously, because loss of status is a governance risk before it is a tax risk.
How much is the subscription tax of an SPF?
It is 0.25%, with an annual floor of EUR 1,000 and a ceiling of EUR 125,000. It is declared and paid quarterly to the registration duties, estates and VAT authority. The base and exemptions are checked with a tax adviser.
Can an SPF hold a property?
Not directly. Property can be held only through capital companies. This rule is dealt with before the acquisition, because a direct purchase takes the structure outside its perimeter.
Does an SPF need a resident manager?
No single rule imposes it in every case, but substance, the place of effective management and bank expectations make a manager who is actually present very useful. A resident manager documents decisions and answers banks and administrations.
What do you do, and not do, for an SPF?
I check eligibility, coordinate the set-up, keep registers and accounting and hold the manager mandate. I do not draft deeds, I do not give binding tax opinions and I do not advise on investments: neither investment advice nor portfolio management.

Read next

Related pageStructuring your business in LuxembourgHolding, SOPARFI, SPF, reorganisation.Read →Related pageFamily wealth transmissionGovernance between generations.Read →Related pageLocal manager in LuxembourgResident manager and substance.Read →ReferenceEstablishment authorisation 10077275The nine activities and the official register.See the authorisations →

Describe what you hold and what you want to do with it.

One page on the assets, flows and people concerned is enough for a first answer, under NDA.

Open an SPF discussion →