How the DGT's position has evolved
Current position
For an entity not to be considered a wealth management entity, it must carry out a real economic activity. This implies that the participation in investee entities must not be counted as securities if at least 5% of the voting rights are held, the direction and management of the participation is exercised, and there is an organization of material and human resources for such purpose.
The DGT's position remains constant in requiring that entities do not have the object of managing movable or immovable wealth to access tax benefits. The evolution shows a transition from requirements of mere non-dedication to management towards a requirement to prove an economic activity through the availability of material and human resources for the management of holdings.
Turning points
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Introduces specific criteria to qualify the activity as economic, requiring that the management of holdings has an organization of material and human resources and a minimum of 5% of voting rights.
Analysis based on 38 of 39 rulings with a stated position. Updated 23 September 2026.