How the DGT's position has evolved
Current position
Wealth alteration occurs at the moment the transfer or the dissolution of the company takes place. In cases of dissolution due to insolvency proceedings, the alteration occurs with the court order decreeing the dissolution. The resulting gain or loss must be attributed to the tax period in which said alteration occurs.
The DGT's position remains constant regarding the timing of imputation, always linking it to the moment of wealth alteration. Recent rulings reinforce that in judicial corporate dissolution processes, the milestone is the court order. No changes in criterion are observed, but rather a repeated application of the concept of wealth alteration in different scenarios.
Analysis based on 46 of 47 rulings with a stated position. Updated 15 September 2026.