A financials shareholding company is not in legal terms, a specific form of company.

It is constituted as an SA (plc) or a SARL (Ltd Co.) or any other form of joint stock company.

The purpose of the company may simply be holding shares in other companies, but also, the management of licences and patents and of debenture loans granted to subsidiaries.

It is authorised to exercise a commercial activity, unlike a standard HOLDING company (Law 1929) or a family assets company (SPF in the French acronym).


Dividends received by the SOPARFI originating from its shareholdings in resident or non-resident capital companies are exempt from the deduction at source under certain conditions.

SOPARFI holds a share of at least 10% in the capital of the subsidiary or a valorisation of a minimum of €1.2 million.

The subsidiary company may be resident or foreign but located in a European Union Member State.

The SOPARFI must retain its shareholding for twelve months or undertake to retain the shareholding for the said period.

Dividends paid by SOPARFI to a parent company:

Dividends paid to a parent company are exempt from the deduction at source if the beneficiary parent company is a resident company fully taxable or located in a State with which the Grand Duchy has concluded an agreement on avoiding double taxation (or an international convention).

The capital gain on disposal of shareholdings in subsidiaries satisfying the aforementioned conditions is exempt if the SOPARFI holds at least 15% of the capital.

The liquidation bonus paid to shareholders or partners in the SOPARFI following its liquidation is tax exempt.

The liquidation bonus paid to SOPARFI on liquidation of a subsidiary is not taxed.

Other activities:

In the event of activities ancillary to retention of shareholdings, notably of a commercial nature, these are liable to corporation tax and VAT.