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The query asks whether the new 19% withholding obligation on the transfer of subscription rights also applies to rights acquired from third parties. The DGT rules that the obligation to withhold only applies to rights held by the taxpayer by virtue of their status as a shareholder.
Question raised 1. Scope of the obligation to withhold and, in particular, whether it is applicable to the transfer of subscription rights previously acquired from third parties.
The obligation to withhold or make a payment on account of 19% refers solely to the transfer of subscription rights arising from securities owned by the taxpayer. Therefore, the transfer of subscription rights previously acquired from a third party does not give rise to the obligation to perform a withholding. In the event of transferring homogeneous rights, the depository entity shall apply the order of transfer set forth in Article 37.2 of the LIRPF, considering that the first to be transferred are the oldest (arising from previously deposited securities) and withholding shall be applied to them.
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