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The DGT confirms that a holding company can only claim exemption from the Wealth Tax on the proportion of assets directly necessary for its business activity, including those related to real estate managed by a subsidiary.
Question posed: Whether the exemption in Wealth Tax applies to the entirety of the holdings in the holding company, given the link existing between the two subsidiaries, since one leases to the other the real estate property where the latter carries out its activity.
The exemption in Wealth Tax shall only apply to the value of the holdings in the proportion existing between the assets necessary for the conduct of the business activity (net of their debts) and the value of the entity's net equity. To determine whether the holding company manages real estate assets, holdings in the subsidiary that carries out economic activity shall not be counted as such values, whereas holdings in entities that do not carry out such activity shall be. The real estate property of a subsidiary is considered part of its own assets and not those of the holding company.
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