How the DGT's position has evolved
Current position
To qualify for the exemption in Wealth Tax, the taxpayer must perform management functions with remuneration exceeding 50% of their total income (business, professional, and personal labor income). The entity's main activity cannot be the management of movable or immovable property, and the participation must be at least 5% individually or 20% jointly. Income attributed through transparent entities must not be included in the 50% calculation.
The DGT's position remains constant regarding the remuneration requirements and management functions for the Wealth Tax exemption. The evolution shows greater technical precision in delimiting which income is counted for the calculation of the 50% percentage, specifically excluding profits from transparent entities.
Turning points
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Establishes that if the taxpayer owns several entities that meet the requirements, the 50% percentage is calculated separately for each one.
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Clarifies that for the calculation of the 50% remuneration for management functions, income attributed by a transparent entity must not be included.
Analysis based on 17 of 17 rulings with a stated position. Updated 26 September 2026.