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V0660-19 ·26 March 2019 ·consulta-vinculante Medium impact
Tax

Distribution of share premium reserve is fully taxable for the usufructuary of the shares

A taxpayer holding the usufruct of shares through a fideicommissary substitution asks how to calculate the income from the distribution of the share premium reserve. The DGT rules that the rule for reducing the acquisition value cannot be applied and the full amount must be taxed as income.

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2019-03-26PublishedPublished 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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