The split is tabled, not valued
There is no room to negotiate here and no place for a valuer. Article 13 of the IMT Code sets the percentage to be deducted from the full ownership value according to the age of the person on whose life the right depends. What is deducted is the value of the usufruct; what remains is the value of the bare ownership.
The logic is obvious once stated: the younger the usufructuary, the longer the usufruct is expected to run and the more it is worth. At twenty the usufruct represents 80% of the value of the property and the bare ownership only the remaining 20%. From eighty-five onwards the relationship is very nearly reversed.
Where there are several usufructuaries, the age used is that of the oldest or of the youngest, according to whether the right ends on the death of any one of them or of the last survivor.
