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V1872-25 14 October 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · valores homogéneos

Shares of the same issuer listed on different markets and currencies are homogeneous values

A taxpayer asks whether shares of the same Danish company, acquired on different markets (Denmark and Germany) and in different currencies (danish kroner and euros), are homogeneous values. The DGT confirms that they are.

The question raised

Whether those shares are considered homogeneous securities for Personal Income Tax purposes.

The DGT's ruling

Class B shares of the same company that have the same nominal value, nature, rights, and transfer regime maintain their character as homogeneous securities even if they are acquired in different European Union markets with different currencies. The difference in currency is an accessory aspect according to Article 8 of the RIRPF, as the price is determined according to the exchange rate with the currency of the issuing company.

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