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A professional receives the right to purchase shares from a client at a price below market value as payment for their services. The DGT determines that this constitutes income from an economic activity in kind.
Question posed: How is the delivery of such shares through the exercise of the aforementioned program taxed under Personal Income Tax.
The granting of stock options as remuneration for services within an economic activity is classified as income from economic activities in kind. If the options are non-transferable, the income is the positive difference between the market value of the shares on the date of exercise and the price paid. The exemption for the delivery of shares to active workers does not apply. The market value at the time of exercise shall be the acquisition value for future capital gains or losses.
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