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A taxpayer inquired about the acquisition value of a property inherited as bare ownership in 1982, where the usufruct was consolidated in 2020 following the death of the usufructuary. The DGT clarifies that the extinction of the usufruct does not constitute a new acquisition, but rather the recovery of rights of enjoyment, and determines how to calculate the acquisition value and any potential reduction based on seniority.
Question posed: They request to know the acquisition value in order to determine the possible capital gain or loss for Personal Income Tax purposes regarding the transfer carried out in 2022.
The extinction of the usufruct due to the death of the usufructuary does not constitute a new acquisition, but rather the owner recovers the rights of enjoyment. The acquisition value shall be the value of the full ownership resulting from the Inheritance and Gift Tax regulations (not exceeding market value), plus investments, improvements, and inherent expenses. As it was acquired before 1994, the transitional regime for reduction under the ninth transitional provision of the LIRPF could apply.
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