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V2113-20 24 June 2020 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Share delivery as variable remuneration must be valued at market value on the date of receipt

A query was raised regarding how to value the portion of variable remuneration paid through the delivery of company shares. The DGT ruled that these shares constitute benefits in kind and must be valued at their market value on the date they are received.

The question raised

How should the valuation be determined for the remuneration consisting of the delivery of half of each payment corresponding to the plan, in company shares.

The DGT's ruling

The free delivery of shares to employees is classified as employment income in kind. Pursuant to Article 43 of the Personal Income Tax Law (LIRPF), its valuation must be carried out based on the market value of the shares on the date of receipt.

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