Family office in LuxembourgOverview
The Law of 21 December 2012 on family office activity, in force since 2 January 2013, defines family office activity as providing advice or services of a patrimonial nature, on a professional basis, to individuals, families and the wealth entities they own or found. It covers wealth organisation and planning, administrative and financial supervision and the coordination of other service providers, but not holding client cash or securities or providing investment services, which remain subject to the Law of 5 April 1993 on the financial sector. Offices created by one family for itself, or serving only one family, are outside its scope, as are corporate directorships and acting as trustee, protector, foundation council member or fiduciary agent.
Anyone else must either belong to a listed regulated profession (credit institutions, investment advisers, private portfolio managers, certain specialised PFS, Luxembourg lawyers, notaries, statutory auditors and chartered accountants) or obtain a separate authorisation as a PFS-Family Office under Article 28-6 of the 1993 Law. That authorisation is granted by the Minister of Finance after review by the Commission de Surveillance du Secteur Financier (CSSF), which then supervises the firm. Only legal entities qualify, with share capital of at least EUR 50,000, central administration in Luxembourg, suitable shareholders and experienced, reputable managers. The law also imposes remuneration transparency, AML/CFT duties and professional secrecy, and makes misuse of the 'family office' title a criminal offence.
Most single-family offices are not visible as such: they take the form of a holding and investment platform. A typical architecture combines a SOPARFI (a fully taxable company using the participation exemption and treaty network) or an SPF (a tax-exempt private wealth company for passive financial assets), one or more SCSp or SCS partnerships for co-investments, and where outside or institutional capital is involved, a RAIF, SIF or SICAR. Recital 7 of the AIFM Directive confirms that family office vehicles investing the family's private wealth without raising external capital are not AIFs, which often allows an unregulated structure. Luxembourg has no domestic trust law, but recognises foreign trusts under the Hague Trust Convention and offers the fiducie.
Recent changes matter for planning. From 2025 the SPF regime was tightened by Bill 8414 (higher minimum subscription tax, administrative fines of up to EUR 250,000 and possible withdrawal of SPF status), corporate income tax fell to 16% (23.87% aggregate in Luxembourg City), and the minimum net wealth tax for holding companies was cut. The Law of 23 January 2025 restricted access to the beneficial ownership register to authorities, obliged professionals and persons with a legitimate interest. The 2027 budget bill presented on 7 October 2026 proposes a further cut to 15% (22.80% aggregate). On 14 October 2026 the Chamber of Deputies voted to repeal the investor residence permit (Bill 8586), so relocation now runs through self-employed, private-means or employment routes.
Key benefits
- Clear perimeter: a single-family office is outside the 2012 Law, and multi-family services follow a defined licensing path rather than informal practice
- Wide choice of vehicles: SPF, SOPARFI, SCSp/SCS, RAIF, SIF and SICAR cover passive wealth, operating holdings, co-investments and institutional pooling
- EU and EEA access: Luxembourg funds and their managers can use AIFMD passports where the family later opens structures to third-party investors
- Holding tax efficiency: participation exemption for qualifying dividends and gains at SOPARFI level, and only a capped subscription tax for an SPF
- Deep service ecosystem of depositaries, administrators, auditors, notaries and private banks in one financial centre
- AAA-rated, politically stable eurozone jurisdiction with a predictable legislative process
- Graduated privacy: beneficial-ownership data is filed with the RBE but, since 2025, no longer open to the general public
Requirements
- Scope test: confirm whether the office serves only one family and its entities (outside the 2012 Law) or offers patrimonial advice or services professionally to several families (regulated)
- MFO route: belong to a listed regulated profession, or obtain PFS-Family Office authorisation under Article 28-6 of the 1993 Law from the Minister of Finance on the CSSF's review
- PFS-Family Office: legal entity with share capital of at least EUR 50,000, central administration in Luxembourg, at least two managers of good repute and adequate experience, transparent shareholding and approved auditor
- Separate licences where activities go further: portfolio management or investment advice require MiFID-type authorisation; managing an AIF for outside investors requires an authorised or registered AIFM
- Remuneration transparency towards clients, professional secrecy and protection of the 'family office' title under the 2012 Law
- AML/CFT under the Law of 12 November 2004: risk assessment, KYC, source-of-wealth and source-of-funds checks, ongoing monitoring and suspicious activity reporting to the FIU
- Beneficial owners declared to the RBE (Law of 13 January 2019, amended by the Law of 23 January 2025); trusts and fiducies administered in Luxembourg registered with the RFT (Law of 10 July 2020)
- CRS (Law of 18 December 2015) and FATCA (Law of 24 July 2015) classification and reporting, plus DAC6 reporting of cross-border arrangements where hallmarks apply
- SPF conditions: only eligible investors (individuals managing private wealth, their wealth entities or intermediaries), no commercial activity, no direct real estate, no interference in portfolio companies, annual AED certificate by 31 July
- Annual accounts filed with the RCS; audit where size thresholds are exceeded or the vehicle is regulated; quarterly subscription tax returns for SPF, SIF and RAIF
Structure designs
Single-family office company (unregulated)
A Luxembourg S.à r.l. or S.A. employing the family's own team to coordinate advisers, report and run governance for one family. Outside the 2012 Law, but any regulated investment service provided to third parties would still need a licence.
PFS-Family Office (multi-family)
Share capital from EUR 50,000
For independent offices serving several families. Authorised by the Minister of Finance, supervised by the CSSF, with Luxembourg central administration, two qualified managers and full AML, governance and reporting frameworks.
SPF private wealth company
Subscription tax min EUR 1,000, max EUR 125,000 a year
Suits passive portfolios of financial assets held by individuals. Exempt from corporate income, municipal business and net wealth tax, taxed at 0.25% on capital and premiums; no treaty access, no real estate and no commercial activity.
SOPARFI holding with SCSp co-investments
Fully taxable company with treaty and EU directive access for operating businesses, private equity and real estate, often paired with tax-transparent SCSp partnerships to give branches or co-investors separate economic interests.
RAIF or SIF family fund
EUR 1.25 million minimum capital within 24 months; well-informed investors from EUR 100,000
For families pooling with friends, co-investors or institutions, or wanting a regulated-standard wrapper. A RAIF needs an authorised AIFM but no CSSF product approval; a SIF is CSSF-authorised. Subscription tax 0.01%.
Fiducie or foreign trust with Luxembourg holding
Succession layer for families from common-law or civil-law backgrounds: a Luxembourg fiducie or a foreign trust holding the SOPARFI or SPF, registered with the RFT where administered in Luxembourg.
Step-by-step process
- 1
Family and asset review
Map family members, residences, citizenships, asset classes and objectives, and confirm whether the office will serve one family or several. This determines licensing, tax residence and reporting from the outset.
- 2
Structure design and tax analysis
Choose the holding vehicle (SPF, SOPARFI or both), any partnerships or funds and the succession layer, and test the result against the tax rules of each family member's country of residence, CFC rules and treaty positions.
- 3
Governance documents
Draft articles, shareholder or partnership agreements, the family charter, investment policy and investment committee terms, and decide who sits on boards locally.
- 4
KYC and incorporation
Complete bank and notary due diligence, deposit share capital, execute the notarial deed and register with the RCS, then file beneficial owners with the RBE and, for an SPF, notify the AED.
- 5
Licensing where required
For a multi-family office, prepare the PFS-Family Office file for the CSSF: programme of operations, shareholders, managers, organisation, AML procedures, business plan and auditor appointment.
- 6
Substance and operations
Lease office space, hire or second staff, appoint the administrator, depositary or AIFM where relevant, open bank and custody accounts and set up CRS/FATCA classification.
- 7
Ongoing compliance
Annual accounts and audits, subscription and corporate tax filings, RBE updates within statutory time limits, AML reviews and periodic review of the structure as the family and the rules change.
Typical documents
- Certified passports and proof of residential address for founders, directors and beneficial owners
- Source-of-wealth narrative with supporting evidence (company sale agreements, dividend history, inheritance documents, audited accounts)
- Bank reference letters and, where requested, a professional reference
- Family tree and chart of the existing holdings and trusts
- Draft articles of association, partnership agreement or fund documents (issuing document, subscription agreement)
- Proof of share capital deposit (blocking certificate) for the notary
- CVs, criminal record extracts and declarations of honour for directors and managers
- For a PFS-Family Office: programme of operations, three-year business plan, organisation chart, AML/CFT procedures and auditor's acceptance letter
- Tax residence certificates and US-person status declarations for CRS and FATCA classification
- Family charter, investment policy and investment committee terms of reference
How Legal Wealth helps
Legal Wealth works with the family and its existing advisers to decide whether a Luxembourg platform is the right fit and, if so, which combination of vehicles serves the family's assets and succession goals. We coordinate Luxembourg counsel, notaries, administrators and banks, prepare the KYC and source-of-wealth file with discretion, map licensing and reporting obligations before anything is incorporated, and connect the structure to residence planning and to companion jurisdictions such as Liechtenstein or Switzerland where that serves the family. Our approach is compliance-first: every structure is designed to withstand bank, tax-authority and regulatory scrutiny in every country where family members live.
Enquire with Legal WealthFrequently asked questions
Does a single-family office in Luxembourg need a licence?
Not under the 2012 Family Office Law, which excludes offices created by or serving only one family and its entities. A licence is still required if the office carries out other regulated activities for third parties, such as portfolio management, investment advice or managing a fund with outside investors.
What is the difference between an SPF and a SOPARFI?
An SPF is a private wealth company for passive financial assets: it pays no corporate income tax but a 0.25% subscription tax (minimum EUR 1,000, maximum EUR 125,000), cannot hold real estate directly or trade, and has no treaty access. A SOPARFI is a normally taxed company (16% CIT in 2025–2026, 23.87% aggregate in Luxembourg City) that can rely on the participation exemption, double tax treaties and EU directives, so it suits operating and private-equity holdings.
Is a family investment vehicle an AIF?
Recital 7 of the AIFM Directive states that family office vehicles investing the private wealth of investors without raising external capital are not AIFs. Once capital is raised from outside the family, the vehicle is likely to be an AIF and a RAIF, SIF or other regulated structure with an AIFM becomes relevant.
Can a family office help us move to Luxembourg?
The investor residence permit is being repealed: the Chamber of Deputies adopted Bill 8586 on 14 October 2026. Non-EU family members now use routes such as the self-employed permit, residence for private reasons or employment, for example as staff of the family office. Qualifying hires may benefit from the impatriate regime, which from 2025 exempts 50% of gross annual pay, capped at EUR 400,000.
Who can see the family's details in the beneficial ownership register?
Since the Law of 23 January 2025 took effect on 1 February 2025, the RBE is no longer open to the general public. Access is limited to national authorities, professionals carrying out due diligence, journalists and organisations with a legitimate interest, and similar groups set out in the law.
How does Luxembourg combine with other jurisdictions?
Families often keep investment management or the operating office in Switzerland, hold succession assets in a Liechtenstein foundation or foreign trust, and use Luxembourg for holding, co-investment and fund vehicles with EU access. Each layer must be tested against the tax rules of the countries where family members live, including CFC and exit tax rules.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
Sources
- CSSF – Press release 13/03 on the Law of 21 December 2012 on family office activity
- Guichet.lu – Subscription tax (taxe d'abonnement) for UCIs, SIFs, RAIFs and SPFs
- Chamber of Commerce opinion on Bill 6366 (Family Office Law)
- Loyens & Loeff – Luxembourg adopts tax measures to boost its attractiveness (CIT, NWT, SPF)
- Clifford Chance – Law of 23 January 2025 reforming the RCS and RBE
- Loyens & Loeff – Luxembourg Budget 2027 proposed tax measures
