Skip to content
Back to index
V3222-20 28 October 2020 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · transmisión lucrativa

FIFO method applied to identify shares transferred in a gift of securities

The taxpayer asks which acquisition value should be used for donated shares that were acquired in different batches. The DGT rules that when securities are homogeneous, the FIFO (First-In, First-Out) method must be applied to identify which specific securities are being transferred.

The question raised

The inquirer requests to know whether the acquisition value of the donated shares for Personal Income Tax purposes is that of the most recent acquisition to which the donated shares belong, or that of the first ones acquired by application of the FIFO (first in, first out) criterion.

The DGT's ruling

For the identification of transferred securities when homogeneous securities exist, Article 37.2 of the LIRPF shall apply, which establishes that the securities transferred shall be deemed to be those first acquired by the taxpayer. This identification criterion is applicable even in gratuitous transfers such as donations. Furthermore, the resulting capital gain shall be included in the savings tax base.

Book your free first meeting