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The taxpayer, the bare owner of a property acquired for consideration, asks how the consolidation of ownership is taxed following the death of the usufructuary (their mother). The DGT rules that it must be taxed under ITP and AJD rather than Inheritance Tax.
This ruling clarifies that the merger of bare ownership and usufruct due to death is treated as an onerous transfer of property, triggering Transfer Tax (ITP) and Stamp Duty (AJD) instead of Inheritance Tax.
The tax team reviews your specific situation.
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