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The taxpayer asks whether the donation of the bare ownership of shares carries the same tax consequences as the transfer of full ownership. The DGT rules that, provided the exemption requirements for Wealth Tax are met, no capital gain or loss will arise for Personal Income Tax purposes.
This ruling clarifies that the donation of bare ownership can be tax-neutral for Income Tax purposes if specific Wealth Tax reduction criteria are satisfied, preventing double taxation or unexpected tax liabilities during the split of ownership.
The tax team reviews your specific situation.
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