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V2791-18 ·24 October 2018 ·consulta-vinculante Medium impact
Tax

Trustee taxed on full ownership for ISD and IIVTNU, with taxation for beneficiaries suspended

A query was raised regarding the taxation of fideicommissary substitutions in Inheritance and Gift Tax (ISD) and the Tax on the Increase in Value of Urban Land (IIVTNU). The DGT ruled that the trustee must pay based on full ownership if they have the power to dispose of the assets, whereas the obligation for the beneficiaries remains suspended until the death of the trustee.

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2018-10-24PublishedPublished 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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