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V0796-26 9 April 2026 · SG de Tributación de las Operaciones Financieras Criterion in force
IRPF · valores homogéneos

Different fund classes with varying fees are not homogeneous values

The consultant asks whether different classes (A and B) of the same investment fund, with different ISINs and fees, are homogeneous values for applying the FIFO rule. The DGT responds that they are not, as the fee differences affect the liquidation value and are not incidental.

The question raised

Question raised 1. Whether shares belonging to different classes of the same investment fund can be considered homogeneous securities for the purposes of applying the FIFO criterion.

The DGT's ruling

Shares of different classes within the same compartment are not homogeneous securities if they have different management fees, as this affects the net asset value and is not an accessory element. Therefore, the FIFO criterion cannot be applied between them. Likewise, shares from different issuers are not homogeneous securities among themselves.

Apply this to a real case

What is published here, applied to a company or a specific case. The first meeting is free.

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