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MEDIUM
FISCAL

Free creation of a life-term usufruct over shareholdings deemed capital movable income

V1320-25

Prepared and reviewed by the BMC editorial team  ·  Methodology

Technical details

Type
consulta-vinculante (what is this?)
Identifier
V1320-25
Published
15 Jul 2025

Summary

A taxpayer enquires about the tax treatment of establishing a free life-term usufruct over limited company shares in favour of relatives. The DGT states that such income is classified as capital movable income and that, being gratuitous, it will be presumed to be remunerated unless proven otherwise.

In 6 key points

Lifecycle

2025-07-15PublishedPublished 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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