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V0662-25 ·14 April 2025 ·consulta-vinculante Low impact
Tax

Application of Spanish regulations and the Convention with France in the valuation of usufructs and bare ownership

A Spanish resident asks which law applies to assessing a French usufruct and when tax arises. The DGT states that Spanish law and the Spain-France double taxation treaty apply, with tax arising based on the nature of the usufruct.

In 6 key points

How it affects those involved

The ruling clarifies the tax treatment of usufructs over foreign property under Spanish law and international agreements.

Lifecycle

2025-04-14PublishedPublished 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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