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A taxpayer inquired whether selling a credit right to a specialised company for a price lower than the debt's value is subject to Personal Income Tax (IRPF). The Directorate General for Taxes (DGT) ruled that such a transfer constitutes a change in assets.
Cuestión planteada Tributación de la transmisión en el IRPF.
La transmisión de la titularidad de un derecho de crédito a cambio de un precio inferior al adeudado constituye una alteración en la composición del patrimonio. La ganancia o pérdida patrimonial se determina por la diferencia entre el valor de transmisión (el importe real satisfecho, siempre que no sea inferior al de mercado) y el valor de adquisición (el importe adeudado).
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