Partner-attended · reply within 24 business hours
Corporate transactions, capital markets and strategic deals.
Independent assessment and rigorous valuation of assets and businesses.
Business reinvention, sustainability and wealth management.
Corporate governance, succession and transformation
International tax planning and cross-border structuring.
Regulatory compliance and tax reporting obligations.
Special regimes for individuals and digital assets.
Tax defense and wealth taxes
Corporate immigration, ICT transfers, investor residency, digital nomad and regularisation.
Employment relations, mobility and regulatory protection.
Protection, compliance and digital resilience
Data protection, DPO and AI regulation
Company formation, contracts, shareholder agreements and corporate operations.
Contracts, dismissals, redundancies and labour court representation.
Insolvency proceedings, fresh start, micro-enterprise procedure and dissolution.
Litigation, arbitration, mediation, IP and real estate law.
Accounting, reporting and outsourced financial management.
Entity management, governance and personnel administration.
Incorporation, incentives and business acceleration.
Risk management, continuity and recovery
New guides on the latest Spanish tax and immigration developments.
Practical tools for informed decision-making.
A query is made regarding the valuation and application of reductions in the donation of bare ownership of shares and the subsequent consolidation of ownership. The DGT clarifies that the double tax benefit may be applied and how taxation must be handled upon the death of the usufructuary.
Question posed: Valuation and settlement in Inheritance and Gift Tax regarding the acquisition of bare ownership of shares. Taxation at the moment of consolidation of ownership. Application of the reduction both upon the acquisition of bare ownership and upon the consolidation of ownership upon the death of the usufructuary. Receipt by the donor and usufructuary of remuneration for the performance of representative and executive functions in subsidiary entities.
In the donation of bare ownership, the value is the difference between the real value and the usufruct, applying the average tax rate of the full value. Upon consolidation of ownership due to death, taxation is based on the value attributed to the bare ownership at its inception, applying the average tax rate and any remaining reductions. The double tax benefit is possible if the requirements of Law 29/1987 and the Wealth Tax exemption are met. Performing management functions in subsidiaries does not prevent the reduction if the business activity requirements are met within the donated entity.
Partner-attended · reply within 24 business hours
Quick message
We reply within 24 business hours. Confidential handling guaranteed.
Google Meet
Direct slot with the partner. Complimentary consultation · no commitment · cancel up to 24h in advance.
Loading availability…
We're fully booked for the next 14 days.
That's a good sign, and we won't leave you hanging.
Request callback
Tell us a time window and a phone number. A partner will call you back during the chosen slot.
< 24 h reply · direct with partner
Have a specific question? Tell us your situation in a sentence or two: a partner will reply within 24 business hours.
Complimentary 30-minute meeting with the partner responsible for your area. Google Meet or in person. Cancel up to 24h in advance.
Loading availability…
We're fully booked for the next 14 days.
That's a good sign, and we won't leave you hanging.
Tell us your preferred time slot and a phone number. A partner will call you back, with no hold queues and no gatekeepers.
We use our own and third-party cookies to improve your experience. More information
Essential for the website to function. Cannot be disabled.
Help us understand how you use the site to improve it.
Enable relevant content and advertising.