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An entity has requested a ruling regarding the tax base for acquiring the bare ownership of properties through life annuity payments. The DGT has determined that the transfer of bare ownership is subject to ITPAJD (Inheritance and Gift Tax), whereas the establishment of the annuity is exempt from this tax as it is subject to VAT.
This ruling clarifies the tax treatment for real estate transactions involving the separation of bare ownership and usufruct, distinguishing between the transfer of property rights and the establishment of annuity payments.
The tax team reviews your specific situation.
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