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V1230-25 4 July 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · ganancias y pérdidas patrimoniales

Transfer of a credit right at a price below nominal may cause a patrimonial loss

An investor asks how to tax in the IRPF the economic loss from selling their credit portfolio on a lending platform. The DGT states that the transfer of a credit right generates a capital gain or loss.

The question raised

Taxation in Personal Income Tax (IRPF) of the result of the sale.

The DGT's ruling

The transfer of ownership of a credit right to a third party entails an alteration in the composition of the assets. The change in assets is determined by the difference between the transfer value (the actual amount effectively paid, provided it is not lower than the market value) and the acquisition value (the amount owed).

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