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V0145-26 27 January 2026 · SG de Impuestos Patrimoniales, Tasas y Precios Públicos Criterion in force
IP · exención

Requirements for remuneration for management functions for the exemption of holdings in Wealth Tax

The taxpayer asks how to compute directorial earnings in a holding company structure to meet the directorial functions requirement. The tax authority states that remuneration received from subsidiaries prior to restructuring shall not be included for the exemption.

The question raised

Calculation of the income received by the taxpayer in the 2025 fiscal year, upon the incorporation of the holding company, for the purpose of verifying, with respect to the holdings in the holding company, compliance with the principal source of income requirement provided for in section c) of Article 4.Eight.Two of the Wealth Tax Law.

The DGT's ruling

For the holding exemption, remuneration for management functions received in the participated companies during the same fiscal year is not included. This criterion applies when the performance of functions is successive and without interruption following a restructuring. The objective is tax neutrality.

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