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V1131-14 22 April 2014 · SG de Tributación de las Operaciones Financieras Criterion in force
IRPF · rendimientos del capital mobiliario

Acquisition value of shares received through subordinated debt conversion shall be the subscription price set by the FROB

The applicant inquires how to calculate the acquisition value of shares obtained following the conversion of subordinated bonds. The DGT rules that such conversion generates income from movable capital and that the new shares shall have an acquisition value equal to the subscription price established in the FROB resolution.

The question raised

Acquisition value of the shares for the purpose of calculating the capital gain derived from the sale thereof.

The DGT's ruling

The conversion of subordinated debt into shares generates income from movable capital based on the difference between the repurchase price and the acquisition value of the debt. For future transfers, the acquisition value of the shares received shall be the subscription price established in the FROB Resolution. Capital gains derived from the sale of these shares may not be offset against negative income from movable capital.

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