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V0437-26 ·27 February 2026 ·consulta-vinculante Medium impact
Tax

Free usufruct on shareholdings presumed remunerated for income tax

A taxpayer asks about the tax treatment of creating a free lifelong usufruct on their shareholdings in favour of their children. The DGT states that such a usufruct is classified as income from movable capital and is presumed remunerated unless proven otherwise.

In 6 key points

Lifecycle

2026-02-27PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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