Skip to content
Back to index
V0420-26 26 February 2026 · SG de Tributos Locales Criterion in force
OTRO · iivtnu

Consolidation of ownership by extinction of usufruct is not subject to IIVTNU

The DGT confirms that there is no taxable event as there is no transfer of ownership or real rights, only a recovery of powers by the bare owner.

The question raised

Taxation of the consolidation of ownership in the Tax on the Increase in Value of Urban Land.

The DGT's ruling

The extinction of the usufruct due to the death of the usufructuary does not constitute a transfer of ownership or real rights, but rather a recovery of the rights of enjoyment by the bare owner. Since no transfer or creation of rights occurs, the taxable event of the ITPdV does not arise. For future transfers, the period for calculating the increase in value shall be counted from the date on which the bare ownership was acquired.

Book your free first meeting