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V1564-23 ·6 June 2023 ·consulta-vinculante Medium impact
Tax

The exemption for lucrative transfer does not apply to succession agreements of particular attribution with present transfer

The inquirer asks whether the transfer of social shares through a succession agreement of particular attribution (with present transfer) is exempt from capital gains tax in the Personal Income Tax (IRPF) as a lucrative transfer due to death. The DGT responds that, as it is legally considered a donation, it constitutes an inter vivos transfer and cannot benefit from said exemption.

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2023-06-06PublishedPublished 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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