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The applicant asks whether the value of shares in a labour company agreed upon by the partners can be considered the market value for Personal Income Tax (IRPF) purposes. The Directorate General for Taxes (DGT) responds that the amount actually paid may be used if it is proven to coincide with what independent parties would have agreed under normal market conditions.
This ruling provides legal certainty for partners of labour companies regarding the valuation of share transfers, allowing for the use of agreed prices provided they reflect arm's length transactions.
The tax team reviews your specific situation.
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