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Legal

Dismemberment of Ownership

Legal division of ownership between usufruct (right of use and income) and bare ownership (ownership without enjoyment).

Full definition

Dismemberment of ownership is a legal technique that consists of dividing the ownership right into two distinct parts: usufruct and bare ownership. This separation makes it possible to optimise wealth transfer and taxation.

The usufructuary retains the right to use the property and receive its income (rents), while the bare owner holds the property without being able to enjoy it immediately. When the usufruct ends (death of the usufructuary or agreed term), the bare owner automatically recovers full ownership.

In Luxembourg, dismemberment is particularly used in the context of gifts (gift with reserved usufruct) and life annuity sales (occupied life annuity). It makes it possible to significantly reduce gift or inheritance taxes, as only the value of the bare ownership is taxed. The tax scale defines the respective value of the usufruct and the bare ownership according to the usufructuary's age.

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