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V2444-25 11 December 2025 · SG de Impuestos Patrimoniales, Tasas y Precios Públicos Criterion in force
IP · actividad económica

Holiday accommodation with complementary services may constitute an economic activity for exemption from Wealth Tax

The consultant asks whether the operation of non-hotel accommodations with additional services constitutes an economic activity entitling to exemption from Wealth Tax participations. The DGT states that if hotel industry services are provided, the activity may be considered economic regardless of having full-time staff.

The question raised

Whether the operation of non-hotel accommodation developed by the entity in which the taxpayer holds an interest constitutes an economic activity, as it involves the self-organized management of means of production and/or resources for the purpose of intervening in the effective and continuous provision of temporary rental and complementary services, with the real allocation of real estate, facilities, and equipment, it being irrelevant whether a full-time employee is engaged under the terms provided for in Article 27.2 of the Personal Income Tax Law.

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