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A taxpayer transfers the ownership of a loan held against a company to a third party for an amount lower than its nominal value. The DGT rules that the difference between the transfer value and the acquisition value constitutes income from movable capital.
Cuestión planteada Tributación en el IRPF de la cesión.
La cesión del derecho de crédito de un préstamo a un tercero comporta la calificación de rendimientos del capital mobiliario de la diferencia entre su valor de transmisión y su valor de adquisición. Estos rendimientos se consideran renta del ahorro conforme al artículo 46.a) de la Ley del IRPF.
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