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V0191-16 20 January 2016 · 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 is determined by the pre-existing shares from which they originate

A query was raised regarding how to determine the seniority of shares acquired through fully paid-up bonus issues and rights issues. The DGT clarifies that the seniority of bonus shares depends on the pre-existing shares that give rise to them, and addresses how capital reductions affect the acquisition value.

The question raised

Seniority of shares for the purposes of the transfer carried out.

The DGT's ruling

In the transfer of homogeneous securities, the FIFO method is applied. The seniority of fully paid-up shares shall be determined by the seniority of the last pre-existing share required to obtain each new share. In capital increases through the purchase of rights, the seniority shall be the subscription date of the new shares. Regarding capital reductions with the return of contributions, the amount must reduce the acquisition value of the affected securities without altering their seniority, provided that said value is not exceeded.

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