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A taxpayer has requested clarification regarding the tax treatment of the dissolution and liquidation of their single-member limited company. The Directorate General for Taxes (DGT) has ruled that the operation constitutes a change in the shareholder's assets, which must be taxed as a capital gain or loss.
Cuestión planteada Tratamiento fiscal en el Impuesto sobre la Renta de las Personas Físicas del consultante de la mencionada operación.
La disolución y liquidación de una sociedad genera una ganancia o pérdida patrimonial para los socios. Esta se determina por la diferencia entre el valor de mercado de los bienes y derechos recibidos y el valor de adquisición de la participación de capital. Dicho resultado se integrará en la base imponible del ahorro del contribuyente.
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