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A taxpayer received a payment under an agreement with a bank to compensate for negative returns from a share conversion and procedural expenses. The DGT determines that the entire amount must be taxed as capital gains, based on the savings base.
Cuestión planteada Tratamiento fiscal en el Impuesto sobre la Renta de las Personas Físicas de la cantidad total estipulada en el acuerdo.
La cantidad estipulada en el acuerdo, tanto la destinada a compensar rendimientos negativos como la destinada a compensar gastos del procedimiento, se considera rendimiento del capital mobiliario. Este importe debe integrarse en la base imponible del ahorro y tributar en el período impositivo en que sea exigible para el cliente.
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