How the DGT's position has evolved
Current position
The delivery of fully paid-up bonus shares does not constitute income from movable capital. For future transfers, the acquisition value is determined by dividing the total cost among the number of old shares and the bonus shares. The seniority of the bonus shares shall be that corresponding to the shares from which they originate.
The DGT's position has remained constant since 2014. All analyzed rulings confirm that the operation does not generate income and that the total cost must be prorated among all shares, maintaining the seniority of the original shares.
Analysis based on 16 of 16 rulings with a stated position. Updated 26 September 2026.