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A physical person with shares in a holding company that itself has subsidiaries asks whether the wealth tax exemption applies. The DGT responds that the exemption applies only to the holding and does not allow counting subsidiary remuneration when calculating exemption thresholds.
Question raised: Admissibility of the exemption in Wealth Tax, calculating the remuneration received regardless of whether it is paid by one or both of the subsidiaries and/or by the holding company.
The exemption in Wealth Tax may only refer to the holding company provided that the requirements of Law 19/1991 are met. It is not possible to apply the exclusion of remuneration from other entities for the calculation of the exemption because the taxpayer is not the direct holder of the shares in the subsidiaries. Therefore, the exemption is limited to the holding company and the remuneration obtained in said company.
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