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A query was raised regarding whether real estate owned by a subsidiary, which leases it to other group companies, should be considered part of the assets used for the Wealth Tax exemption of a holding company. The DGT ruled that, as the subsidiary does not carry out its own economic activity, its shares are not entitled to the exemption and affect the holding company's calculation.
Question posed: Whether, for the purposes of the exemption from Wealth Tax on the holdings of the "holding company", said real estate must be considered used for economic activities.
The subsidiary that only leases real estate does not carry out an economic activity; therefore, its holdings do not qualify for the exemption. For the holding company, if the majority of its assets consist of these holdings, it will not be able to apply the exemption. If the holding company does qualify for the exemption, its objective scope will not include the value of the real estate owned by the leasing subsidiary.
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