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A taxpayer wishes to establish a gratuitous life usufruct over 50% of a company's shares in favour of his father. The DGT rules that this transaction generates income from movable capital, which must be valued at fair market value.
This ruling clarifies that the establishment of a usufruct without consideration is subject to taxation as income from movable capital, requiring an assessment based on market value rather than nominal value.
The tax team reviews your specific situation.
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