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V2899-15 ·6 October 2015 ·consulta-vinculante Medium impact
Tax

Properties leased by a holding not considered part of economic activity for IP exemption if no permanent staff

The DGT responds that, in the absence of employees with full-time labour contracts, property leasing does not constitute economic activity, and thus the properties cannot be considered part of the economic assets.

In 6 key points

How it affects those involved

Holding companies leasing property without employing staff may not qualify for the patrimonial tax exemption due to the absence of economic activity.

Lifecycle

2015-10-06PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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