Over 1,000 structures supported, 17 years of experience, results guaranteed.
Thinking about a business in Luxembourg? The SOPARFI company Luxembourg is a popular choice. It is a strong and flexible business structure. This is a fully-fledged Luxembourgish company. It is under regular corporate law. Many international groups use it.
Luxembourg's SOPARFI, Société de Participations Financières, is the holding vehicle of choice for international groups, private equity funds, and family offices seeking a credible, tax-efficient European base. Governed by the Companies Act of 1915 and subject to standard Luxembourg corporate taxation, it combines legal robustness with genuine structural flexibility.
The core appeal lies in Article 166 of the Luxembourg Income Tax Law (LIR): dividends received from qualifying subsidiaries and capital gains on their disposal are fully exempt from Luxembourg corporate income tax — provided the parent holds at least 10% of the subsidiary's capital, or acquires a participation with a minimum cost of €1.2 million, maintained for an uninterrupted period of 12 months. Luxembourg's network of over 80 double tax treaties reinforces this efficiency by substantially reducing withholding taxes on cross-border dividend flows, interest, and royalties.
Unlike a pure SPF (reserved for private wealth management), a SOPARFI can conduct operating activities alongside its holding function: intra-group financing, IP management under the Article 50ter IP Box regime, treasury pooling, and consulting services. This dual capacity makes it genuinely useful as a regional headquarters rather than a passive vehicle.
Post-BEPS, demonstrating real economic substance in Luxembourg is non-negotiable for tax authorities and banking partners alike. Key decisions must be taken locally, board meetings held in Luxembourg, and management functions genuinely exercised on-site. Our independent director service ensures your structure meets both the legal threshold and the expectations of the ACD.
Incorporation requires a notarial deed, minimum share capital of €12,000 for an SA (or flexible amounts for a SARL), and registration with the Trade and Companies Register (RCS). Our team manages the full process — from drafting statutes to opening your blocked capital account.
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Fiduciaire Financial Services Accountant Luxembourg Trusted reliable strategic long term partner in Luxembourg. Over 17 years of experience in strategic structuration Tailored support for your accounting, tax, and business needs. RCS: B213987 VAT LU29299810 Autorisation : 10077274/2 and 10077274/0