How the DGT's position has evolved
Current position
To access the reduction for the transfer of shares, the donor must be entitled to the exemption in Wealth Tax. This requires exercising management functions with remuneration exceeding 50% of their total income (including business, professional, and employment income, both in Spain and abroad). Furthermore, the donor must cease to exercise such functions and receive such remuneration following the transfer.
The DGT's position remains constant regarding the requirement of management functions and remuneration for the exemption. The evolution shows greater technical precision by integrating all income (national and foreign) to calculate the remuneration threshold and by clarifying that the exemption also applies to civil societies.
Turning points
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Establishes that for the remuneration requirement for management functions, all business, professional, and employment income must be considered, both in Spain and abroad.
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Specifies that the exemption is applicable to holdings in civil societies under the income attribution regime and defines that the remuneration must exceed 50% of the taxpayer's income.
Analysis based on 37 of 43 rulings with a stated position. Updated 16 September 2026.