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A taxpayer over 65 years of age inquires whether the Personal Income Tax exemption for the donation of holdings applies whether full ownership or bare ownership of the shares is donated. The DGT responds that the treatment is the same for both scenarios provided that the requirements of the Inheritance and Gift Tax Law are met.
Question posed: Whether the provisions of Article 33.3.c) of the Personal Income Tax Law may be applicable to the donation, both in the case where full ownership of the shares is donated, and in the case where the bare ownership of the same is donated while reserving the usufruct.
In the donation of the bare ownership of shares in a company, the same tax treatment applies as in the transfer of full ownership. Therefore, no capital gain or loss shall be assessed for Personal Income Tax purposes for the donor, provided that the requirements of Article 20.6 of Law 29/1987 are met. This criterion is independent of whether the donee applies or not the reduction in the Inheritance and Gift Tax taxable base or of the requirements of regional regulations.
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