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V0078-21 22 January 2021 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · acciones liberadas

Issuance of fully paid bonus shares does not constitute income and preserves the original shares' holding period

The applicant asks whether receiving bonus shares instead of cash dividends triggers taxation on the dividend and whether that amount should be used as the acquisition value. The DGT rules that the issuance of fully paid bonus shares does not generate income and that the total cost is allocated between the original and new shares.

The question raised

Question posed: Whether the shares received in exchange for waiving the distribution of dividends would have as their acquisition value the amount of the waived dividend and as their acquisition date the date of said dividend.

The DGT's ruling

The issuance of fully paid-up bonus shares does not result in the receipt of income for the shareholder. The acquisition value of the new shares and the old shares shall be the result of dividing the total cost by the number of securities (old and bonus shares). The acquisition date of the bonus shares shall be the same as that of the shares from which they originate. In the event of waiving the shares and opting for cash dividends, these shall be taxed as income from movable capital.

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