Spanish Wealth Tax (WT) taxes individuals’ net worth, i.e. assets directly owned by them minus charges and encumbrances which might diminish its value.

Non-tax-residents in Spain are only taxed with WT on assets held in Spain.

In this case (binding consultation V3178-19), a non-resident individual owns all shares in a foreign company. Such company is the sole shareholder of a Spanish company who then owns a property in Spain. The Spanish company owns no other assets and undertakes no on-going business in Spain.

Given the above particulars, the individual only owns directly the shares in the foreign company and therefore owns directly no assets in Spain and consequently is not subject to WT.