How the DGT's position has evolved
Current position
In Wealth Tax (Impuesto sobre el Patrimonio), the exemption requirements must be met at the time the donation accrues. In inter vivos acquisitions, the family control percentage requirement must exist in the tax period prior to the donation. It is not necessary for a period of time to elapse following the donation to validate the exemption.
The sequence presents scattered criteria regarding different tax reductions (donations, leases, pension plans, and insurance). There is no doctrinal evolution regarding a single concept, but rather isolated criteria for different matters. The position on the exemption in Wealth Tax (Impuesto sobre el Patrimonio) remains focused on the requirement of meeting criteria at the time of accrual.
Analysis based on 24 of 25 rulings with a stated position. Updated 24 September 2026.