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A query was raised regarding whether the consolidation of ownership following the death of a usufructuary generates income for Corporate Tax purposes, and whether the contribution of bare ownership of shares to a company may qualify for the special regime. The DGT ruled that consolidation does not generate taxable results and that the contribution may apply the special regime provided that legal requirements are met and its sole purpose is not to obtain a tax advantage.
Question posed: Whether there is income to be included in the tax base of the Corporate Income Tax as a consequence of the consolidation of ownership in the event of the death of the holder of the usufruct.
The consolidation of ownership through the extinction of the usufruct, according to the General Accounting Plan, values elements at their acquisition cost, and therefore does not determine results in the profit and loss account or in the tax base. The contribution of bare ownership of shares may qualify for the special regime for non-monetary contributions if the requirements of Article 87 of the LIS are met and the operation does not have the primary objective of tax fraud or evasion (Article 89.2 LIS).
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