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V1613-25 15 September 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · ganancias y pérdidas patrimoniales

Losses from foreign exchange fluctuations governed by one-year period under LIRPF article 33.5(e)

The consultant asks whether foreign exchange variation losses are subject to the 2-month or 1-year period in article 33.5 of the LIRPF. The DGT confirms that article 33.5(e) applies, setting a one-year period for loss recovery.

The question raised

In the event of losses incurred due to exchange rate fluctuations, to determine whether Article 33.5 of Law 35/2006 on Personal Income Tax is applicable and which time limit applies (2 months or 1 year).

The DGT's ruling

Capital losses arising from exchange rate differences in the conversion of foreign currencies into euros are governed by the provisions of letter e) of Article 33.5 of the Personal Income Tax Law (LIRPF). Therefore, the time limits set forth in letters f) or g) regarding securities or holdings do not apply. The loss shall not be recognized if the transferor reacquires the assets within the year following the transfer.

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