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A query was raised regarding whether the obligation to pay taxes arising from the termination of a life usufruct begins at the moment of the usufructuary's death and whether this responsibility falls upon the bare owner. The DGT ruled that the usufruct is extinguished by death and that the bare owner is the party liable for payment.
Question posed: Whether the obligation to pay the taxes derived from the extinction of the life usufruct and the consolidation of full ownership arises at the moment of the usufructuary's death and corresponds to the holder of the bare ownership.
The usufruct is extinguished at the moment of the usufructuary's death. At that instant, the bare owner is the party obligated to pay for the consolidation of ownership, as full ownership is consolidated in them.
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