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The query asks whether titles received after a split retain the original acquisition date to meet the one-year holding period requirement. The DGT responds that, under the regulations, the received values retain the acquisition date of the original titles.
Question posed: Whether, in accordance with Article 81.2 of Law 27/2014, by virtue of which the securities received shall retain the acquisition date of those transferred, the S5 securities will have the same seniority as the S2 securities, i.e., more than one year, whereby the transferred interest could access the exemption regardless of the time at which it was carried out.
In merger and spin-off operations, the securities received are valued for tax purposes at the tax value of those transferred. Likewise, said securities shall retain the acquisition date held by the transferred securities, specifically for the application of Article 21 of the Corporate Income Tax Law.
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