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A U.S. resident asks whether capital gains from the sale of shares in a Spanish company with deferred pricing can be taxed as payments become due. The DGT responds that temporary imputation rules cannot be applied.
Question posed: Whether the capital gain derived from the transfer through installment sale of securities must be taxed by the IRNR as the corresponding payments become due.
Spain has the authority to tax capital gains from the transfer of shares in Spanish companies according to the Convention with the USA. The tax accrues when the change in assets takes place. The TRLIRNR does not contemplate rules for temporal imputation for installment operations nor does it refer to the IRPF regulations, therefore the income cannot be imputed proportionally as the payments become due.
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