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V1731-24 15 July 2024 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · acciones totalmente liberadas

Acquisition value and seniority of fully paid-up shares are determined by the original shares

A taxpayer requested guidance on how to calculate the acquisition value and seniority of shares received through fully paid-up capital increases. The DGT ruled that the total cost must be apportioned between the original shares and the newly issued shares, and that the seniority of the new shares shall be the same as that of the original shares from which they originate.

The question raised

Acquisition value and holding period of shares received in capital increases for the purpose of calculating capital gains or losses in Personal Income Tax.

The DGT's ruling

In the case of fully paid-up bonus shares, the acquisition value of these and those resulting therefrom shall be the result of dividing the total cost by the number of securities, including both the original and the bonus shares. The holding period of the fully paid-up bonus shares shall be that corresponding to the shares from which they originate. Specifically, the holding period of each new bonus share shall be determined by the holding period of the last pre-existing bonus share necessary for its acquisition.

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