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V1132-21 ·28 April 2021 ·consulta-vinculante Medium impact
Tax

Family business tax reduction cannot apply to lifetime succession agreements if the deceased has not passed away

The inquirer asks whether succession agreements made during their lifetime (inter vivos transfers) can benefit from the reduction under Article 20.2.c) of the LISD. The DGT rules that they cannot, as the death of the transferor is an indispensable requirement for said reduction.

In 6 key points

How it affects those involved

This ruling clarifies that the tax benefits associated with family business transfers are strictly contingent upon the death of the transferor, preventing the application of these reductions to lifetime succession pacts.

Lifecycle

2021-04-28PublishedPublished 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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