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A partner enquires about the tax treatment of a free share purchase option granted after rendering services. The DGT determines that if the option arises from services generating work income, the income is recognised at the time of exercising the option.
Question posed. The following issues are consulted for the purposes of Personal Income Tax (IRPF):
If the call option is granted free of charge and derives from services that give rise to employment income, the income shall be determined at the time of its exercise. This is quantified by the difference between the market value of the shares at the time of exercise and the price paid. The market value is the price agreed upon between independent parties. Said value shall be the acquisition value for future transfers.
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