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V2747-18 ·17 October 2018 ·consulta-vinculante Medium impact
Tax

Positive difference between net asset value and acquisition cost in tax havens constitutes income imputation

A shareholder in a collective investment scheme located in a tax haven has requested clarification on how to tax the positive difference between the net asset value at the end of the period and its acquisition cost. The Directorate General for Taxes (DGT) has ruled that this difference constitutes an income imputation that must be included in the general tax base.

In 6 key points

How it affects those involved

This ruling clarifies the tax treatment for investors in offshore collective investment schemes, ensuring that unrealised gains (based on NAV increases) are treated as taxable income in Spain.

Lifecycle

2018-10-17PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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