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The consultation concerns the taxation of improvement and separation agreements under Galician Civil Law. The DGT determines that while these agreements constitute succession titles for Inheritance and Gift Tax, if there is immediate delivery of assets, the transaction is treated as an inter vivos transfer for Income Tax (IRPF) purposes.
This ruling clarifies that the timing of asset delivery determines the tax regime: immediate delivery triggers Income Tax on capital gains, whereas deferred delivery follows inheritance tax rules.
The tax team reviews your specific situation.
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