MEDIUM
FISCAL

Free life usufruct on shareholdings deemed capital mobile income

V0447-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V0447-25
Published
21 Mar 2025

Summary

A taxpayer asks about the tax treatment of creating a free life usufruct on shareholdings in their companies for relatives. The DGT states that this arrangement constitutes income from capital mobile assets and that, being free, there is a presumption of remuneration.

In 6 key points

Lifecycle

2025-03-21PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.
PDF on boe.es

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