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A company holding the bare ownership of an estate seeks clarification on whether it must pay taxes following the consolidation of ownership due to the death of the usufructuary. The DGT determines that there is no tax liability for ISD, ITPAJD, or adjustments to Corporate Tax.
The ruling confirms that the automatic merger of ownership rights upon the death of a usufructuary does not trigger transfer taxes or corporate tax implications for the bare owner.
The tax team reviews your specific situation.
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