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An inquirer asks whether the settlement of rights to the appreciation of a company (transferable options) is a capital gain or employment income. The DGT determines that, as it derives from services rendered, it is remuneration for the performance of their activity.
Question posed: Taxation of said settlement in Personal Income Tax: whether a capital gain is considered to have occurred due to the difference between the acquisition and settlement values of the options and whether said gain is not subject to withholding tax on IRPF.
Payments for rights to the appreciation of the company constitute variable remuneration for the performance of the activity. This amount is employment income pursuant to Article 17.1 of the LIRPF, regardless of the possibility of transferring the right or the existence of an initial outlay. As it is employment or economic activity income, it is subject to withholding tax on IRPF pursuant to Article 75 of the IRPF Regulation.
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