Skip to content
Back to index
V2509-25 16 December 2025 · SG de Impuestos Patrimoniales, Tasas y Precios Públicos Criterion in force
ITPAJD · operaciones societarias

Liquidation of a society with real estate assignment to shareholders is subject to ITPAJD

An heir who has received shares from a society owning two properties seeks advice on the taxation of the society's liquidation. The DGT determines that the assignment of assets to shareholders constitutes a corporate transaction subject to tax.

The question raised

Taxation of the operation.

The DGT's ruling

The dissolution and liquidation of the company with the adjudication of assets to the partners is an operation subject to the corporate operations modality of the ITPAJD. The taxpayer is the partner for the assets received. The taxable base is the value of the assets and rights delivered, without deducting debts or expenses, and the tax rate is 1 per 100.

Book your free first meeting