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MEDIUM
FISCAL

A temporary usufruct over shares is deemed capital mobile income

V0673-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V0673-25
Published
15 Apr 2025

Summary

A taxpayer donated a five-year temporary usufruct of their shares to their children, retaining the bare ownership. The DGT considers this transaction as capital mobile income, not as an increase in wealth.

In 6 key points

Lifecycle

2025-04-15PublishedPublished 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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