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V5169-16 29 November 2016 · SG de Tributación de las Operaciones Financieras Criterion in force
IRPF · rendimientos del capital mobiliario

Foreign currency note holding base is the difference between original and euro-denominated values

A taxpayer asks how to calculate the return and retention of a note linked to stock indices denominated in dollars. The DGT responds that the return is the difference between the acquisition and amortisation values in dollars, converted to euros at the exchange rate at the time of cancellation.

The question raised

Question posed: Whether the method of carrying out the settlement corresponding to the nominal amount of the note and, consequently, the withholding applied to the result of said settlement, is correct.

The DGT's ruling

The returns on the note are returns on movable capital from the transfer of own funds. To calculate the return, the difference between the redemption or reimbursement value and the acquisition value must be determined in the currency of denomination of the asset, converting said difference into euros at the exchange rate in force at the time of cancellation. The withholding base shall be the positive difference between both values in the monetary unit of the asset, converted into euros at the exchange rate at the time of cancellation.

Apply this to a real case

What is published here, applied to a company or a specific case. The first meeting is free.

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