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A taxpayer purchased the bare ownership of a property, and upon the death of the usufructuary, full ownership was consolidated. The DGT ruled that the taxpayer must pay tax on the remaining percentage of the property's value.
Cuestión planteada Tributación de la consolidación del dominio sobre la vivienda.
Al consolidarse el dominio por muerte del usufructuario, el nudo propietario debe tributar por transmisiones patrimoniales onerosas por el porcentaje que no tributó al adquirir la nuda propiedad. Este porcentaje se aplica sobre el valor real del inmueble en el momento de la consolidación. El impuesto se liquida en la Comunidad Autónoma donde radique el inmueble.
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