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V0144-26 27 January 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IRPF · partes vinculadas

Sales of collection motorcycles by partners to the company must be valued at market value

Partners in a company wish to sell their collection motorcycles to the company itself to launch a new commercial activity. The DGT states that, as the parties are related, the transaction must be valued at market value to determine the capital gains or losses for income tax purposes.

The question raised

1. Impact on the Personal Income Tax of the selling partners in the motorcycle purchase and sale transaction.

The DGT's ruling

As there is a link between the partners and the company, the sale and purchase of the motorcycles must be carried out at their market value. For Personal Income Tax purposes, the transaction will generate capital gains or losses based on the difference between the acquisition and transfer values. The transfer value shall be the actual amount, provided it is not lower than the normal market value.

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