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A taxpayer whose subordinated debt was converted into shares to be immediately transferred to a buyer without receiving any consideration seeks clarification on the tax treatment. The DGT determines that this must be treated as a single redemption operation of the bonds.
Cuestión planteada Tratamiento en el IRPF de las referidas operaciones.
La conversión de obligaciones en acciones para su transmisión inmediata sin contraprestación se trata como una amortización de las obligaciones. Esto genera un rendimiento del capital mobiliario negativo por la diferencia entre el valor de adquisición y el valor de amortización (cero euros). Dichos rendimientos negativos se integran y compensan en la base imponible del ahorro.
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