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A taxpayer inquired whether periodic fees for investment portfolio management services are deductible as expenses against income from movable capital. The Directorate General for Taxes (DGT) ruled that they are not deductible, as they relate to active management rather than mere administration and custody services.
Question posed Given that the aforementioned fees are paid periodically, and therefore are not implicit in the result obtained when the portfolio is liquidated, it is asked whether they can be considered a deductible expense from the return on movable capital in the Personal Income Tax for the corresponding period.
Active management fees aimed at portfolio revaluation through the selection and execution of disposal acts are not deductible administration and custody expenses. Article 26.1.a) of the Personal Income Tax Law expressly excludes discretionary and individualized portfolio management. Furthermore, these fees are not considered expenses inherent to acquisition or transfer for the purpose of calculating capital gains or losses, as they are periodic payments linked to the global value of the portfolio.
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