What is a SPF? What type of investments can be placed into a SPF? What type of investors can invest into a SPF?

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1 THE SPF

2 What is a SPF? SPF stands for Société de Gestion de Patrimoine Familial. The SPF is a tax neutral investment company which sole purpose is the management of the private wealth of individuals. The company may be seen as an extension of the private wealth of individuals. However, as the SPF is a company with a legal personality different from those of its shareholders, the responsibility of an investor/shareholder is limited to the assets contributed to the company. What type of investments can be placed into a SPF? Forbidden activities are, among others: Any type of commercial activity; Granting of loans: the SPF is not allowed to render any kind of services, including granting interest bearing loans, even to companies in which the SPF holds a participation. However, it may make cash advances or guarantee the liabilities of a company in which it holds a participation, but only on an ancillary basis and without remuneration; Holding of intellectual property: the SPF is not authorised to hold any type of intellectual property directly; Holding of real estate: the SPF may not invest directly into real estate. However, it may acquire holdings in corporations or other non-transparent entities that own real estate. As the SPF is an extension of the private wealth of its investors, its activities are limited to those generally expected from individuals managing their financial assets. Based on the SPF Law, the SPF is able to perform the following activities: Holding of financial assets: acquisition, holding, management and disposal of financial assets (e.g. shares in companies, other securities equivalent to shares/units in companies and undertakings for collective investment, bonds and other forms of debt instruments, cash and assets of any kind held in a bank account, investments in structured products or derivatives, put/call options on securities, indexes and currencies). Holding of participations: the SPF can also hold participations in the share capital or the voting rights of other companies, but only to the extent that the SPF is not involved in the management of these companies. The SPF is therefore not allowed to perform any management role in its subsidiary. There are however no restrictions as regards to the activity of the company in which the SPF may hold a participation. What type of investors can invest into a SPF? The SPF is exclusively designed for investors managing their private wealth. The shares of the SPF cannot be used for public placement and cannot be quoted on a stock exchange. The benefits of the SPF regime is not open to corporate investors and it cannot be used within a corporate group. Eligible investors within the meaning of the SPF Law are: a. individuals managing their private wealth, or b. private wealth management entities acting for one or several individuals (trust etc.), or c. intermediaries acting on behalf of a) or b). Private wealth management entities are intended to include (but not exclusively), entities such as trusts, foundations, stichtings or any other such type of entity, to the extent that their purpose is the management of the private wealth of one or more individuals. Entities holding the shares of the SPF on a fiduciary basis on behalf of an individual or a private wealth management entity are also eligible investors.

3 How to set up a SPF? The SPF is not a legal form as such. It can be set up as a public limited company (SA), a partnership limited by shares (SCA), a private limited company (Sàrl), or a cooperative company organised under the form of a public limited company. It shall be clearly indicated in the company s articles of incorporation/association that it is a private wealth management company within the meaning of the SPF Law. SPFs are subject to the requirements in terms of minimum share capital applicable to ordinary commercial companies (EUR for a SA and SCA and EUR for a Sàrl). How is a SPF regulated? The SPF is not a regulated entity. No authorisation is required prior to the acquisition of the SPF status or to the beginning of its activities as long as the company complies with the specific conditions set by the SPF Law. The SPF is however supervised by the Luxembourg indirect tax authorities ( Administration de l Enregistrement et des Domaines - AED ). The indirect tax authorities are entitled to search and analyse all facts and data in connection with the tax status of the company in order to ensure that the correct amount of taxes is levied. In addition, the SPF needs to have certain points certified on an annual basis by its domiciliary agent or, if there is none, by a chartered accountant ( expert-comptable ) or a certified auditor. It will have to be certified that the investors in the SPF are eligible investors and that the SPF has complied with its withholding tax obligations on interest paid to individuals where applicable. The Law does not formally require the SPF to comply with a specific debt-to-equity ratio. However, since the part of the debt that exceeds eight times the paid-up share capital plus share premium would be taken into account for the computation of the annual subscription tax (as this tax is computed on the capital), the SPF, in practice, often complies with a ratio of maximum 8 of debt to 1 of equity. What are the key tax and legal benefits of a SPF? The SPF is the vehicle of choice for individuals and family offices that wish to pool their assets in a tax neutral investment company. The SPF is not subject to Luxembourg corporate income tax, municipal business tax or net wealth tax. Due to its specific tax regime, the SPF is however not entitled to benefit from the double tax treaties concluded by Luxembourg or from the EU Parent Subsidiary Directive. As a result, any dividend and interest payments on financial assets received by a SPF might be subject to withholding tax, if any, in the State of source in accordance with the domestic tax rules of that State. There is no Luxembourg withholding tax on the distributions of profits made by a SPF to its shareholders. However, payments of interest by a SPF can be subject to withholding tax in certain cases.

4 The SPF is subject to an annual 0,25% subscription tax that is levied on the sum of: the paid-in share capital and share premium of the SPF; and the part of the debt (if any) that exceeds eight times the amount of the paid-in share capital and share premium of the SPF. This means in practice that the SPF is expected to comply with an 8 to 1 debt-to-equity ratio. The subscription tax cannot be lower than EUR 100 and is capped at EUR 125,000 per year. The tax is payable on a quarterly basis. Given its restricted scope of activities, SPFs are not considered by the Luxembourg Authorities as taxable persons for VAT purposes. Finally, the SPF is an extension of the private wealth of individuals that offers its shareholders the benefits associated with the legal personality, i.e. legal liability limited to the assets contributed into the company. Why ATOZ? ATOZ is a Luxembourg high end independent advisory firm offering comprehensive solutions, encompassing the entire life cycle of an investment entity: from tax planning and corporate implementation, management and compliance/maintenance, to exit planning (sale, M&A or dissolution) with a strong focus on alternative investment PE/PERE funds, multinational corporations, financial institutions and high net worth families. ATOZ is very active in the PE sector and is advising multibillion funds investing throughout the world. ATOZ has managed to take advantage of its in-depth knowledge of the industry to propose innovative solutions to the PE industry creating added value for both LPs and GPs. ATOZ is an active member of the Luxembourg Private Equity Association. ATOZ is a founding member of Taxand, the first independent global organisation with tax professionals in nearly 50 countries. Taxand provides high quality, integrated tax advice worldwide. The Taxand tax professionals, nearly 400 tax partners and over tax advisors grasp both the fine points of tax and the broader strategic implications, helping you mitigate risk, manage your tax burden and drive the performance of your business.

5 THE SPF - OVERVIEW LEGAL / REGULATORY REQUIREMENTS BEST PRACTICE STRUCTURE CHART KEY TAX BENEFITS PRIVATE INVESTORS Individuals Private wealth management entities INVESTMENT ADVISOR No WHT on payments to investors (except on interest from savings) STATUTORY SEAT IN LUXEMBOURG MAJORITY OF BOARD MEMBERS LUXEMBOURG RESIDENT SPF SA, SCA, Sàrl, Coop SA CIT Exemption NWT Exemption AUDITOR DOMICILIATION COMPANY/ OFFICE AND ACCOUNTS DRAWN UP IN LUXEMBOURG Subscription Tax 0,25% on share capital + share premium (capped at EUR ) LEGAL / TAX ADVISOR FINANCIAL ASSETS

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