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V1236-25 4 July 2025 · SG de Tributación de las Operaciones Financieras Criterion in force
IRPF · rendimientos del capital mobiliario

Active management and portfolio revaluation fees not deductible in income tax

The consultant asks whether quarterly management and annual portfolio revaluation fees are deductible in income tax. The DGT responds that these fees are not deductible as administration expenses or as expenses inherent to the transfer of securities.

The question raised

Whether the aforementioned amounts paid to the banking entity for the management and revaluation of the portfolio may be subject to deduction in Personal Income Tax or computed to determine the income obtained upon divestment.

The DGT's ruling

Active management commissions for portfolio revaluation are not expenses for the administration and custody of negotiable securities, as they do not constitute mere static administration or commercial custody. They are also not deductible as expenses inherent to the acquisition or transfer of securities, as they are periodic payments linked to the valuation of the portfolio and lack a clear and precise nexus with redemption or transfer operations. Therefore, they cannot be deducted from income from movable capital nor computed to determine capital gains or losses.

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