Updated 13.08.2026
Legal structures · Private foundations
A family foundation in Luxembourgthe SPF structure for capital
In Luxembourg family capital is held through an SPF — a family wealth management company. It owns portfolios, shareholdings and accounts, carries on no commercial activity and pays no tax on profit. The register of beneficial owners is closed to public access.
- We check eligibility under the EU sanctions rules before the work begins
- We say it plainly: an SPF is a company, not a foundation in the classic sense
- We prepare the source-of-funds file for the Luxembourg bank
The guide figures depend on the composition of the assets, the number of beneficiaries and the bank’s requirements. The exact quotation for the set-up and the annual upkeep is fixed before the agreement.
Applicability
Is Luxembourg the right structure for your task
01 Main purpose
02 Assets
03 Beneficiaries
04 Bank account needed
The selector does not give a legal opinion: applicability is confirmed after the analysis of assets, family and tax residence.
The structure
What an SPF is and why it is called a foundation
An SPF is a company created by the 2007 law specifically to manage a family’s private capital. It does not run a business, provide services or trade — it only holds financial assets. Clients and the market call such a structure a «family foundation», although legally it is a company: Luxembourg has no private foundations law of its own.
An SPF owns shares, bonds, fund units, deposits and cash. Commercial activity and the provision of services are prohibited to it — which is exactly why it is exempt from tax on profit.
The property belongs to the company: when it is set up correctly it does not form part of your personal estate directly and passes under corporate rather than inheritance rules.
Following the 2022 judgment of the Court of Justice of the EU, public access to registers of beneficial owners in the EU is closed: the information is available to the competent authorities and to obliged entities on a reasoned request.
Luxembourg is Europe’s largest asset-management centre. Banks and counterparties see a familiar and respected structure.
Fit
Who an SPF suits — and who it does not
A plain filter, sanctions restrictions included.
- You hold an EU passport, EU residence or a citizenship outside the sanctions perimeter
- The capital consists of financial assets: portfolios, fund units, deposits
- You need a European structure with an impeccable reputation for banks
- The task is consolidating family capital and succession by rules
- The assets and the heirs are predominantly in Europe
- Russian or Belarusian citizenship without EU residence: corporate and trust services are prohibited by the EU sanctions regulation
- You need commercial activity: an SPF cannot carry it on, and the whole regime is lost
- The main task is protection from creditors: an SPF is weaker than the Cook Islands and Nevis trusts
- The assets are an operating business or real estate: a different structure is needed
Roles
How an SPF is arranged
A corporate model: the organs of a company instead of trust roles.
The individual or structure that owns the SPF’s shares. The range of permitted holders is limited by the law.
The company’s governing body: it takes decisions on the assets within the articles.
A licensed Luxembourg professional: the address, the reporting, the dealings with the register.
The family and the heirs — through holding the shares or under the rules of corporate and succession planning.
Protection
The legal limits of using the structure
The strengths together with the limits — and with the sanctions reservation.
All the family’s financial assets are gathered in one person with a clear ownership structure.
There is no public access to the register of beneficial owners: the information is disclosed to the competent authorities on request.
A structure from Luxembourg is accepted by European banks and counterparties without further explanation.
The handover of the shares is planned in advance, bypassing lengthy inheritance procedures.
The limits we state plainly: an SPF is weaker than a trust at protecting against creditors — it is a holding company, not a «fortress». It does not cancel your tax obligations and it takes part in the exchange of information. Separately and firmly: for citizens of Russia and Belarus without residence in the EU the provision of corporate and trust services is prohibited by the European Union’s sanctions regulation — we do not work around that restriction and we offer lawful alternatives outside the EU.
Prices
The options for the structure and the cost
The «from» prices are for a standard structure with a confirmed source of funds and eligibility under the sanctions rules.
from $18,500
Annual upkeep: upkeep thereafter from $9,000 a year
Consolidating the family’s portfolios and deposits
Included
- A check of eligibility under the EU sanctions rules
- Formation of the SPF and its articles
- The domiciliary agent and the address — the first year
- The corporate documents
- Notarial and registration fees
from $24,500
Annual upkeep: upkeep thereafter from $11,500 a year
A structure with banking already in place
Included
- Everything in the «SPF» package
- The source-of-funds file for the bank
- Opening an account with a Luxembourg or Swiss bank
- Support through the compliance procedures
from $32,000
Annual upkeep: upkeep thereafter from $14,000 a year
Family capital in Europe with a succession plan
Included
- Everything in the «SPF + account» package
- A plan for passing the shares to the heirs
- Coordination with notaries in the countries of the assets
- Annual reporting and support
- The rules for distributions
The package does not include: the subscription tax on the capital, the bank’s own charges, an audit where one is required, or legal work in the countries of the assets.
What drives the quote
The factors that affect the cost of the project
The packages cover the standard tasks. Here is what moves the budget — and it is counted before the agreement, not after.
The annual subscription tax is calculated on it — the main variable in the upkeep budget.
Portfolios and deposits are simple. Shareholdings in operating companies need an extra check for compatibility with the SPF regime.
EU residence, citizenships and tax residences affect the volume of checks and whether the structure is permissible.
Banks differ in what they require: for some the basic pack, for others an extended file.
In the quotation we separate our own fee, the domiciliary agent’s charges and the notarial and government fees. The total is fixed by the agreement.
Cost of ownership
The cost of the structure over three years
A structure costs money not only when it is created: administration, reporting and bank compliance recur every year.
- Creating the structure and the documents
- Registration and government fees
- Opening the structure’s bank account
- The first year of administration
- Administration of the structure
- Reporting and mandatory notifications
- Bank compliance and the KYC refresh
- Support of distributions to beneficiaries
- Administration of the structure
- Reporting and mandatory notifications
- Bank compliance and the KYC refresh
- A review of the structure as circumstances change
What each year contains depends on the jurisdiction, the assets and the bank’s requirements. We prepare the three-year calculation together with the set-up quotation — before the agreement.
Tax
Taxation, reporting and disclosure
An SPF is exempt from tax on profit and from wealth tax, but pays an annual subscription tax on its capital. Your own obligations are determined by your country of residence.
Instead of tax on profit an SPF pays an annual subscription tax calculated on the size of its capital. The exact figure is calculated for your structure.
Providing services and trading strip the company of the SPF regime. That is the key restriction, and we keep to it in the design.
Shares in a foreign company are declared, and where there is control the CFC rules apply.
Luxembourg takes part in the automatic exchange: information on accounts goes to the holders’ country of residence.
We do not build arrangements to conceal income and we do not work with funds whose origin is not evidenced by documents.
Banking
The banking infrastructure of the structure
Luxembourg is Europe’s banking centre, and the account is opened in the same country in which the company is registered.
Banks in Luxembourg and Switzerland are the main option for this structure.
Who holds the shares, where the capital came from, what the purpose of the structure is, whether there are sanctions factors.
The European documentation standard: a chain for every source is mandatory.
For clients with Russian or Belarusian citizenship the bank checks for EU residence — without it the account will not be opened.
A refusal by a bank is not the end: we work out the reason and go to the next one with the file corrected. No one guarantees approval, and neither do we.
Documents
Documents and information for the establishment
We assemble the pack once — the same pack goes to the administrator and to the bank.
- 01Personal documents Passports and proof of address: the founder, the foundation council, the beneficiaries.
- 02The source of the capital Sale agreements, bank statements, dividend resolutions, tax returns.
- 03The list of assets What is going into the structure: accounts, portfolios, real estate, shareholdings — with the title documents.
- 04Tax residence The countries and the taxpayer numbers of every party: the notifications and the reporting depend on them.
- 05The rules for distributions Who receives funds, when and on what conditions — these rules go into the constitutive documents.
- 06Current obligations Claims, debts, guarantees and disputes: they determine whether the protection works at all.
No documents are needed at the first consultation — we work through the task in words.
Comparison
Compare Luxembourg with other structures
| Luxembourg | |
|---|---|
| Setup | from $18,500 |
| Annual | upkeep thereafter from $9,000 a year |
| Timing | 3-5 weeks |
| Typical use | You hold an EU passport, EU residence or a citizenship outside the sanctions perimeter |
Select up to two jurisdictions above. A detailed legal comparison is prepared for the specific task.
Process
The stages of establishing the structure
From the review of the task to a finished structure with an account.
What is being protected or consolidated, who the beneficiaries are, whether there are current disputes. We say plainly whether the structure is needed at all.
1-2 daysThe roles, the rules for distributions, the controller’s powers, exactly what is transferred and how.
3-5 daysIdentity documents and source-of-funds evidence for the administrator and the bank.
1-2 weeksThe constitutive documents, the appointment of the officers, registration.
3-5 weeksMoving the assets into the structure with correct formalities in the countries where they are held.
Opening the structure’s account and setting the rules for the work that follows.
Comparison
Luxembourg against the alternatives
The main parameters side by side, so that the choice is an informed one.
| Luxembourg SPF | Liechtenstein | UAE · RAK | Panama | |
|---|---|---|---|---|
| Legal form | Company | Foundation | Foundation | Foundation |
| Jurisdiction | EU | EEA | The Gulf | Latin America |
| Access for Russian citizens | Only with EU residence | Only with EU residence | Open | Open |
| Establishment | 3-5 weeks | 4-6 weeks | 2-3 weeks | 2-3 weeks |
| Cost from | $18,500 | $28,000 | $9,500 | $8,500 |
The comparison is as at the date the page was updated; whether it applies to your case is confirmed once the profile has been reviewed.
FAQ
Questions and answers
Legally it is a family wealth management company (SPF). Luxembourg has no private foundations law of its own: a bill on the Fondation Patrimoniale was introduced in 2013 and never passed. We keep the page in the foundations range because that is how clients search, but we call things by their names.
Without residence in the EU — no: the European Union’s sanctions regulation prohibits the provision of corporate and trust services to citizens of Russia and Belarus. With residence or a second passport outside the perimeter — yes. We check eligibility before the work begins and offer lawful alternatives outside the EU if Luxembourg is closed.
Financial ones: shares, bonds, units in investment funds, deposits, cash. It may not carry on commercial activity, provide services or, as a rule, own real estate directly — other structures are used for that.
There has been no public access to registers of beneficial owners in the EU since 2022, following the judgment of the Court of Justice of the EU. The information is available to the competent authorities and to obliged entities on a reasoned request.
An SPF pays no tax on profit and no wealth tax, but does pay an annual subscription tax on its capital. Your personal obligations are determined by your country of tax residence — the duty to declare and the CFC rules remain.
From $9,000 a year: the domiciliary agent, the address, the reporting. Plus the subscription tax, which depends on the size of the capital. The exact figure is fixed in the quotation before the agreement.
Calculation
Structure and budget: Luxembourg
Describe the assets, the family and the task. We will come back with the applicable structure, the setup budget and the annual upkeep.
A structure does not cancel existing creditor claims or the tax obligations of the settlor. Where the task cannot be solved lawfully, we say so before the engagement.