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V2235-19 ·20 August 2019 ·consulta-vinculante Medium impact
Tax

Successive improvement pacts must not be aggregated for Inheritance and Gift Tax settlement

A query was raised regarding whether multiple improvement pacts involving the transfer of assets during one's lifetime should be aggregated for tax calculation purposes. The Directorate General for Taxes (DGT) ruled that, as there is no legal provision for the aggregation of succession titles, each pact is considered independent.

In 6 key points

How it affects those involved

This ruling provides legal certainty for taxpayers making multiple improvement pacts, ensuring that each transfer is treated as a separate taxable event rather than being combined to increase the tax rate.

Lifecycle

2019-08-20PublishedPublished 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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