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V2051-20 23 June 2020 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · acciones totalmente liberadas

Acquisition value of fully paid-up shares is calculated by dividing total cost by all shares

A taxpayer inquired about calculating the acquisition value of shares received free of charge during a capital increase to determine capital gains. The DGT ruled that while these shares do not constitute income, their cost must be determined by prorating the cost of the original shares across the total number of shares held.

The question raised

Acquisition value of the transferred shares for the purpose of calculating the capital gain derived from said transfer in Personal Income Tax.

The DGT's ruling

The delivery of fully paid-up bonus shares does not constitute income for the taxpayer. For future transfers, the acquisition value of the delivered shares and the original shares shall be the result of allocating the total cost among the number of securities, including both the original and the bonus shares. The holding period of the fully paid-up bonus shares shall be that corresponding to the shares from which they originate.

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