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Management Company: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Refined position High confidence 16 rulings · 2014–2026

Current position

The services of the management company, including marketing and advice on investment strategies, are exempt from IVA (Value Added Tax) provided that the delegation does not turn the management company into an instrumental or empty entity. The exemption requires that the delegated functions constitute a differentiated set of activities essential for management. However, the management and recovery of credits assigned by administrators is considered a taxable and non-exempt activity.

The DGT has maintained a line of exemption for the essential management and marketing functions delegated. The evolution shows a refinement of the criterion to prevent the management company from being an empty entity, integrating the standards of the CJEU jurisprudence. Recently, it has been delimited that the management of assigned credits does not fall within this exemption.

Turning points

  1. V2275-22

    Introduces the condition that the delegation must not turn the management company into an instrumental or empty entity to maintain the exemption.

  2. V0203-26

    Specifies that the management and recovery services of credits assigned by administrators are subject to and not exempt from IVA.

Analysis based on 16 of 16 rulings with a stated position. Updated 26 September 2026.

Rulings on this topic

16
V0046-24 14 Feb 2024

SICC participations may qualify for wealth tax exemption under certain conditions

SG de Impuestos Patrimoniales, Tasas y Precios Públicos
sociedad de inversión colectiva de tipo cerradoexención por actividad económicacoeficiente obligatorio de inversióngestión de patrimonio mobiliariomedios materiales y personales LIP — Ley 19/1991 del Impuesto sobre el Patrimonio art. 4.Ocho.DosLey 22/2014
Affects CompanyExpat · Non-residentIndividual

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