How the DGT's position has evolved
Current position
For the exemption in Wealth Tax, the activity must be the main source of income, which requires that at least 50% of the Personal Income Tax (IRPF) taxable base comes from net income from economic activities. In the case of real estate leasing, it is mandatory to employ at least one person under a full-time employment contract. The activity must be carried out habitually, personally, and directly through the adoption of management decisions.
The DGT's position remains stable in defining the main source of income as the 50% threshold of the IRPF taxable base. A consolidation is observed in the rigor required for real estate leasing, establishing the need to hire a full-time worker for the activity to be considered economic. The doctrine has also specified that dividends are included in this calculation and that the retirement pension does not prevent the exemption.
Turning points
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Clarifies that dividends received as investment income are included to determine the taxpayer's main source of income.
Analysis based on 34 of 38 rulings with a stated position. Updated 23 September 2026.