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The taxpayer asks whether the consolidation of full ownership of a property has expired because the acquisition of the bare ownership had already expired. The DGT rules that these are distinct moments of enforceability and that the limitation period for consolidation begins to run once the usufruct is extinguished.
This ruling clarifies the distinction between the limitation periods for acquiring bare ownership and the subsequent consolidation of full ownership, preventing the loss of rights through the expiration of the former.
The tax team reviews your specific situation.
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