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V2453-25 11 December 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del capital inmobiliario

Grant and exercise of a purchase option create two distinct patrimonial changes

A usufructuary asks whether selling a property after a lease with a purchase option would result in a patrimonial loss. The DGT clarifies that granting the option and the subsequent sale are two independent taxable events.

The question raised

Question posed: It inquires whether that loss can be offset in the following four years in the Personal Income Tax.

The DGT's ruling

The granting of the call option produces a capital gain at the time of its formalization, which must be included in the savings tax base. The subsequent exercise of said option constitutes a new change in assets that generates a different gain or loss, calculated according to the acquisition and transfer values. Both operations are considered transfers of assets as they are not carried out within an economic activity.

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