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The taxpayer asks whether the temporal imputation regime can be applied to the sale of company shares where payment is received in monthly instalments over 10 years. The DGT rules that it is possible to opt for imputing income proportionally as the payments become due.
Question posed: It is requested to know whether the temporal imputation regime referred to in Article 14.2 d) of the Personal Income Tax Law can be applied.
In installment operations or those with deferred pricing, where the period between delivery and the final installment exceeds one year, the taxpayer may opt to proportionally attribute income as the payments become due. In this case, as more than one year elapses between delivery and the final installment, the inquirer may apply said rule.
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