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The private wealth management company (SPF)

Structure	Société à responsabilité limitée (limited liability company), Société anonyme (public limited liability company), Société en commandite par actions (partnership limited by shares).
Sole object	Passive acquisition, holding, management and disposal of financial assets Financing of activities in exchange for remuneration from shareholders or third parties
Unauthorised activities	Commercial activity Interference in the management of interests held by the company Direct ownership of real estate
Eligible investors	Natural persons acting within the scope of the management of their private wealth Wealth management entity acting exclusively in the interests of the private wealth of natural persons Intermediaries acting on behalf of natural persons or a wealth management entity (sub 2)
Supervision	Supervisory authority: Administration de l’Enregistrement et des Domaines (AED, the Luxembourg VAT and Registration Authorities) The domiciliary agent or independent auditor must certify compliance with the law with regard to the eligibility of investors and investments (certificate to be sent to the AED before 31 July of each year)

Exempt from capital duty of 0.5% since 1 January 2009
Subjective exemption => Exempt from corporation tax
Exempt from wealth tax
Subject to annual subscription tax (taxe d'abonnement) of 0.25% of the sum of the paid-up share capital, share premium and the portion of debt that exceeds 8x the sum of the share capital + share premium.
Minimum annual subscription tax = EUR 100 / Maximum = EUR 125,000
The SPF is excluded from the exemption regime if 5% or more of the total dividend income it receives during a financial year is derived from companies who are not subject to a tax that is comparable to Luxembourg corporation tax (i.e. minimum 10.5%)
No withholding tax is payable in Luxembourg on dividends distributed by the SPF
Resident investors are taxed at the full rate, i.e. they are not entitled to the exemption of up to 50% of dividends (art. 115, 15a)
Non-residents are not taxed on the capital gains earned on the sale of units held in an SPF (even in the case of speculative income - cf. certain tax agreements concluded by Luxembourg)
European withholding tax on interest paid to non-resident investors (20% since 1 July 2008)
Final withholding tax of 10% on interest income paid to resident investors

In principle, dividends or capital gains are eligible for taxation at a different rate or exemptions according to the local taxation rules.
For example, in the case of investors resident in Belgium, taxation at a separate rate of 15% should apply to dividends.