Approach

For taxpayers subject to the tax by personal obligation, the sum of the full amount of the Wealth Tax together with the amounts ofIRPFABBR (full general fee and full savings fee)may not exceed 60 percent of the sum of the taxable bases, general and savings, of IRPFABBR.

The amount of the full fees of IRPFABBR is the sum of the amounts shown in the boxes[0545] and [0546]from the statement of IRPFABBR corresponding to the 2025 fiscal year.

The amount of the taxable bases, general and savings, of IRPFABBR is the sum of the amounts shown in the boxes [0435] and [0460] from the statement of IRPFABBR corresponding to the 2025 fiscal year.

With regard to the limit of the full tax liability, the recent Supreme Court ruling of October 29, 2025, appeal no. 4701/2023, is of interest (RED: STS 4849/2025), in which the Supreme Court establishes, in its Legal Basis 4, the following interpretative criterion: “Habitual residence, whether in Spain or abroad, does not justify the different treatment given to residents and non-residents, which consists of the fact that the limit of the full quota provided for in article 31 is not applicable to the latter. One of the Wealth Tax Law. That difference in treatment is discriminatory and unjustified.” Therefore, the aforementioned limit is also applicable to taxpayers subject to the tax by real obligation.