On 4 June 2024, the Luxembourg Tax Authorities (LTA) released
administrative circular L.I.R. n° 159/2 (the
"Circular"), offering important guidance
on the issuance of residence certificates to Luxembourg family
wealth management companies (société(s) de gestion de
patrimoine familial, or "SPF(s)") governed by the Law of
11 May 2007 (the "SPF Law"). This
development is particularly relevant given the unique tax regime
applicable to SPFs under Luxembourg law, as described below.
SPFs are specialized entities designed for individuals managing
their private wealth. As provided by article 1 of the SPF law,
various structures can be chosen from such as a limited liability
company (S.à r.l.), a public limited company ("S.A.), a
corporate partnership limited by shares ("SCA"), or a
cooperative company organized as a public limited company
("SCoSA"), in order to best fit the individual needs.
However, SPFs are restricted to the acquisition, holding,
management, and
