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V1655-21 31 May 2021 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · agrupamiento de acciones

The pooling of shares does not constitute an asset alteration nor does it generate gains or losses for Personal Income Tax purposes

A taxpayer asks whether the pooling of 12 shares into a single share, with the accumulated value of the previous ones, constitutes an asset alteration. The DGT responds that there is no capital gain or loss.

The question raised

Question posed: Whether this operation would imply for the inquirer an asset alteration that would give rise to a capital gain or loss in Personal Income Tax.

The DGT's ruling

The exchange of shares through the pooling of lots into a single share with the accumulated value does not constitute an asset alteration. This is because the new shares incorporate the same economic and political rights as the shares surrendered.

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