The SOPARFI (Société de Participations Financières) is a fully taxable commercial company whose corporate purpose is limited to the holding of participation and related activities. A SOPARFI LU takes advantages of the participation exemption and may benefit from double taxation treaties signed by Luxembourg.
SOPARFIs fall within the scope of the Law of 10 August 1915 (as amended) on Commercial Companies. The SOPARFIs’ tax system is regulated by the General Tax Law of 22 May 1931 (as amended). Due to the fact that SOPARFIs’ primary activity is holding and / or financing activities, it benefits from the Parent-Subsidiary European Directive of 30 November 2011 (2011/96/EU). The EU Directive of 30 November 2011 was designed to eliminate tax obstacles for profit distributions between parent companies and subsidiary based in different Member States. Therefore, the Directive gives a tax exemption for dividends and other profits distribution paid by subsidiary companies to their parent companies.
A Luxembourg SOPARFI may be used to :
- Hold participations in Private Equity;
- Finance other entities
- Hold real estate in Luxembourg or overseas, directly or through a company
- Hold financial assets (financial instruments, bonds for instance)
- Own intellectual property rights to perceive royalties
- Exercise management control over other entities