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V1665-26 19 June 2026 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · ganancia patrimonial

Acquisition value of fully released shares calculated by dividing total cost by number of shares

A taxpayer asks how to calculate capital gain when selling shares without exact purchase values, including shares received as dividends. The DGT clarifies that fully released shares are not income and explains how to determine their acquisition value and holding period.

The question raised

How should the taxpayer proceed to calculate the capital gain or loss to be included in the Personal Income Tax.

The DGT's ruling

The acquisition value of fully paid-up shares is the total cost divided by the number of securities, including both original and paid-up shares, while maintaining the seniority of the original shares. Proof of value and acquisition date may be provided by any means of evidence admitted under Law, with the valuation being the responsibility of the Tax Administration.

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