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V2093-23 ·18 July 2023 ·consulta-vinculante Medium impact
Tax

The gratuitous establishment of a usufruct over shares is classified as income from movable capital

An owner of shares in unlisted companies inquires about the tax treatment of establishing a temporary gratuitous usufruct in favor of family members. The DGT indicates that said operation constitutes income from movable capital and that, being gratuitous, there is a presumption of remuneration.

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2023-07-18PublishedPublished 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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