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A shareholder has enquired whether they can declare a loss resulting from the cancellation of their shares in a capital reduction operation followed by a subsequent capital increase. The Directorate General for Taxes (DGT) has ruled that, as all their shares are cancelled, the acquisition value is considered a capital loss.
Cuestión planteada Si la consultante puede reflejar la pérdida correspondiente a la amortización de las acciones.
Al amortizarse la totalidad de las acciones que el socio posee en la sociedad, no es posible distribuir el valor de adquisición entre otros valores homogéneos. Por tanto, el valor de adquisición de las acciones amortizadas se considera una pérdida patrimonial. Esta pérdida debe imputarse al ejercicio de la reducción de capital e integrarse en la base imponible del ahorro.
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