How the DGT's position has evolved
Current position
To qualify for the exemption in Wealth Tax (Impuesto sobre el Patrimonio), the entity must not have the management of movable or immovable assets as its main activity. The assets required to meet the mandatory investment coefficient of a SICC (Sociedad de Inversión Colectiva de Capital) do not count towards determining said activity. The remaining assets will not count as securities if they represent a minimal part of the investment.
The DGT's position remains constant in requiring that the entity does not primarily manage movable or immovable assets to access the exemption. The criteria for calculating assets have been specified, clarifying that the securities intended to meet the mandatory investment coefficient of a SICC do not count towards determining the company's activity.
Turning points
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Establishes that holdings in entities with economic activity do not count as securities for determining whether the entity manages movable assets.
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Specifies that the securities included in the mandatory investment coefficient of the SICC do not count as securities for determining the asset management activity.
Analysis based on 9 of 10 rulings with a stated position. Updated 28 September 2026.