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A family holding company has queried whether it qualifies as a patrimonial entity. The DGT has ruled that, as it is solely engaged in the management of shareholdings without conducting an economic activity, it will be considered a patrimonial entity if more than half of its assets consist of securities or elements not assigned to an economic activity.
Cuestión planteada Tiene la sociedad A la consideración de entidad patrimonial.
Se considera entidad patrimonial aquella en la que más de la mitad de su activo, según la media de los balances trimestrales, esté constituido por valores o no esté afecto a una actividad económica. La mera gestión y administración de participaciones no constituye actividad económica. Los dividendos percibidos que forman tesorería o inversiones financieras se consideran elementos no afectos para este cálculo.
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