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V3113-19 7 November 2019 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · nuda propiedad

Sale of bare ownership shares deemed a separate transaction from full ownership shares

A query was raised regarding whether the sale of shares held under bare ownership constitutes a different transaction from those held under full ownership. The DGT ruled that the dismemberment of ownership creates two distinct patrimonial realities.

The question raised

For Tax purposes, which shares would be considered sold.

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