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V3528-19 ·23 December 2019 ·consulta-vinculante Medium impact
Tax

A company solely managing shareholdings may be classified as a patrimonial entity

A family holding company has queried whether it qualifies as a patrimonial entity. The DGT has ruled that, as it is solely engaged in the management of shareholdings without conducting an economic activity, it will be considered a patrimonial entity if more than half of its assets consist of securities or elements not assigned to an economic activity.

In 6 key points

How it affects those involved

This ruling clarifies the tax classification for holding companies, establishing that the absence of active economic operations and a high proportion of non-operational assets will trigger patrimonial entity status.

Lifecycle

2019-12-23PublishedPublished 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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