Skip to content
Back to index
V1790-19 11 July 2019 · SG de Tributación de las Operaciones Financieras Criterion in force
IRPF · obligaciones subordinadas

Immediate conversion and transfer of subordinated bonds generates negative returns on movable capital

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.

The question raised

Tax treatment in Personal Income Tax (IRPF) of the aforementioned operations.

The DGT's ruling

The conversion of bonds into shares for immediate transfer without consideration is treated as an amortization of the bonds. This generates a negative return on movable capital due to the difference between the acquisition value and the amortization value (zero euros). Such negative returns are integrated and offset within the savings tax base.

Book your free first meeting