Structures in Luxembourg
Among the various structures, one can find interest
in :
- SOPARFI (société de participation financière)
- Holding 1929 (holding companies)
- Securitisation companies
- SICAR (private equity companies)
- SICAV, SICAF Both the SOPARFI and the Holding 1929 structures are of interest
for tax planning and managing the assets/equities of a group of
companies or family. Using either structure can optimize one’s
tax situation. Below is a summary of their respective advantages
:
| |
SOPARFI |
HOLDING 1929
|
|
Activity |
holding participation: exempt Commercial: taxable |
Portfolio & Participation management, royalties income and patents: exempt |
|
Taxes |
Income tax on commercial activity Fortune tax Capital duty |
Subscription Tax
Capital duty |
|
Conventions |
Yes |
NO |
|
Mother,subs |
Yes |
NO |
|
Inter. Royalt. |
Yes |
NO |
|
Publicity |
Yes |
NO |
|
Anonymity |
Yes |
Yes |
|
Loss deduct. |
Yes |
-n--a- |
The Holding 1929 regime has been modified on 1/7/2005. The benefit
of the Holding 1929 will not be granted anymore from 19/7/2006.
Another regime will
be introduced
|