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V0636-23 17 March 2023 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · valor contable

Acquisition value of fixed assets is the book value, regardless of the previous owner's tax regularisation

A taxpayer inquired about determining the acquisition value of a business (a tobacconist) previously acquired from his wife, whose transfer had been regularised by the Tax Agency. The DGT clarified that the sale of stock constitutes income from economic activity, whereas the sale of fixed assets results in a capital gain or loss based on the book value.

The question raised

Question posed: Acquisition value of the taxpayer's tobacconist shop for Personal Income Tax purposes.

The DGT's ruling

The transfer of inventory generates income from economic activity included in the general taxable base. For fixed assets, the capital gain or loss is calculated as the difference between the transfer value (actual amount or market value) and the book value. The book value must take into account tax-deductible depreciation and must not include the adjustment made by the Administration to the previous owner.

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