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V0192-19 ·29 January 2019 ·consulta-vinculante Medium impact
Tax

Imputation of real estate income applies to daughters acquiring full ownership via an improvement pact

An individual transfers full ownership of several properties to her daughters through an improvement pact, subject to a condition precedent regarding the power to dispose of and encumber the assets. The DGT rules that the imputation of income must be attributed to the daughters as the owners, rather than the transferor.

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2019-01-29PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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