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A taxpayer sells shares with payments via promissory notes over five years and decides to assign that credit right to a bank. The DGT indicates that, by transferring the promissory notes before their maturity, the income must be attributed to the tax year in which the shares were transferred.
Cuestión planteada Imputación temporal de la ganancia patrimonial obtenida en la venta de acciones.
En operaciones a plazos, el contribuyente puede optar por imputar la renta proporcionalmente según la exigibilidad de los cobros. Sin embargo, si los efectos cambiarios (pagarés) se transmiten en firme antes de su vencimiento, la renta se imputará al período impositivo de la transmisión. Al ceder el derecho de crédito y los pagarés al banco, la renta se imputa en el año de la venta de las acciones.
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