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The consultation concerns the taxation of improvement and separation agreements under Galician Civil Law. The DGT determines that while these agreements constitute succession titles for Inheritance and Gift Tax, if there is immediate delivery of assets, the transaction is treated as an inter vivos transfer for Income Tax (IRPF) purposes.
Question raised: Taxation under Inheritance and Gift Tax and Personal Income Tax (IRPF) for both parties. In the case of an improvement agreement, differences if it is carried out with or without the delivery of present assets of the affected property.
Improvement and separation agreements are succession titles subject to Inheritance and Gift Tax. If the improvement agreement includes the delivery of present assets, the tax accrues on the date of the agreement and not upon death. For Personal Income Tax (IRPF), if there is a delivery of present assets, the transaction is considered inter vivos, and therefore the exemption for capital gains from gratuitous transfers due to death does not apply.
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