The exclusive object of a SPF should be the holding and management of financial assets e.g. shares, bonds, derivatives, bank deposits, loans and precious metals. It may not conduct commercial activities, hold intellectual properties or real estate.
Investors are restricted to members of a family, investment clubs, trusts and foundations, or nominees acting on behalf of the aforementioned. Shares cannot be listed, but a SPF may borrow from shareholders, banks and third parties.
A SPF may not receive more than 5 % of its annual dividend income from non-EU entities or from unquoted entities, where these entities are taxed at a rate below 11 %.
The taxation of a SPF is summarised as follows:
- Subscription tax: 0.25 % of paid-up capital and premium
- No income tax
- No withholding tax on dividends
- No capital gains tax on disposal of assets
- Does not benefit from double tax treaties