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V0758-18 21 March 2018 · SG de Impuestos Patrimoniales, Tasas y Precios Públicos Criterion in force
IP · exención

Subsidiaries may pay the remuneration of holding company directors to maintain the Wealth Tax exemption

A query is made as to whether subsidiaries may pay the salaries of holding company executives without losing the Wealth Tax exemption. The DGT responds that this is possible provided it is expressly provided for in the articles of association of both entities.

The question raised

Question posed: Possibility of remuneration for management functions performed by the directors of the holding company being satisfied by the subsidiaries, without loss of the right to the Wealth Tax exemption.

The DGT's ruling

To maintain the Wealth Tax exemption, it is not necessary for the entity in which the management functions are performed to satisfy the remuneration itself. These may be paid by the subsidiaries, provided that the appropriate provision is made in the deed or articles of association of both the parent company and the subsidiaries.

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