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V0135-26 27 January 2026 · SG de Impuestos Patrimoniales, Tasas y Precios Públicos Criterion in force
IP · bienes afectos

Financial resources from capital assignments are not exempt from Wealth Tax

The consultant asks whether their financial resources for advertising can be considered economic assets to qualify for exemption from Wealth Tax and ITSGF. The DGT replies that assets from capital assignments are not economic assets, although bank balances could be if their necessity for the business is proven.

The question raised

Whether the liquid balances and financial resources of the taxpayer, used for the acquisition of advertising spaces and the operational development of the activity, may be considered assets used for economic activity for the purposes of applying the exemption in Wealth Tax and the Temporary Solidarity Tax on Large Fortunes.

The DGT's ruling

Financial resources representing the transfer of capital to third parties are not considered assets used for economic activity under the Personal Income Tax Law (LIRPF); therefore, they do not benefit from exemptions in Wealth Tax or the Temporary Solidarity Tax on Large Fortunes (ITSGF). Regarding liquid balances in bank accounts, their classification as assets used for the activity depends on whether they are truly necessary for the conduct of the activity, and the proportionality of the average balance must be assessed against working capital requirements.

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