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V0045-23 16 January 2023 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · acciones totalmente liberadas

The seniority of fully paid-up bonus shares depends on the pre-existing shares from which they originate

A taxpayer has requested clarification on how to determine the seniority of shares acquired through fully paid-up capital increases and through the purchase of subscription rights. The DGT clarifies that bonus shares retain the seniority of the shares from which they originate, whereas shares acquired via subscription have their own seniority date.

The question raised

Seniority of shares for Personal Income Tax purposes.

The DGT's ruling

For fully bonus shares, their seniority shall be that which corresponds to the shares from which they originate. In the application of the FIFO method, the distribution of bonus shares is carried out according to the seniority and proportionality of the pre-existing shares. On the other hand, the seniority of shares obtained through the purchase of subscription rights shall be the subscription date of said shares.

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