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V1579-25 8 September 2025 · SG de Impuestos Patrimoniales, Tasas y Precios Públicos Criterion in force
ISD · reducción en la base imponible

Reduction of inheritance tax can be maintained by reinvesting proceeds

The consultant asks whether the extinction of a company and the immediate reinvestment of the proceeds in other assets fulfils the ten-year value maintenance requirement. The DGT confirms this is possible if the amount is reinvested immediately in other assets to preserve the acquisition value.

The question raised

It is consulted whether the requirement of maintaining the ten-year period could be understood as fulfilled in the event that the amount obtained from the dissolution of Company A, regarding the portion of shares inherited from its mother, is reinvested in other perfectly identified assets that are always distinct from a simple current account, maintaining the value of the amount received during the ten-year period established by the LISD.

The DGT's ruling

To maintain the reduction provided in Article 20.2.c) of the LISD following the disposal of shares, the immediate reinvestment and materialization of the amount obtained in other assets is required. The requirement does not demand continuity of activity, but rather the maintenance of the acquisition value upon which the reduction was applied. Said reinvestment may be carried out in real estate, shares, investment funds, deposits, or any other financial product. The reinvestment must be as immediate as possible to ensure the maintenance of value.

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