How the DGT's position has evolved
Current position
To access reductions in Inheritance and Gift Tax (ISD), holdings must be exempt from Wealth Tax. This exemption requires that, in joint holdings, at least one member of the kinship group (spouse, ascendants, descendants, and second-degree collaterals) performs management functions. These functions must effectively involve the administration, management, coordination, and operation of the company.
The DGT's position remains constant in requiring the Wealth Tax exemption as a prerequisite. The doctrine has specified the scope of the kinship group and the nature of management functions to ensure compliance. No changes in criteria are observed, but rather a consolidation of the requirements regarding allocation and management.
Turning points
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Specifies that in joint holdings, management and remuneration functions may be fulfilled by at least one of the persons in the kinship group.
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Defines that management functions are fulfilled if they effectively involve the administration, management, coordination, and operation of the company.
Analysis based on 47 of 51 rulings with a stated position. Updated 19 September 2026.