How the DGT's position has evolved
Current position
The savings tax base integrates income from movable capital, such as dividends or life insurance proceeds, and capital gains or losses. Gains or losses are determined by the difference between the acquisition and transfer values, allowing for the deduction of expenses and taxes inherent to the transaction. In cases of corporate dissolution, the capital loss arises from the difference between the acquisition value of the shares and their liquidation quota.
The DGT's position remains constant in the application of the general rules of the LIRPF (Personal Income Tax Law) for determining the savings tax base. The rulings analyze different scenarios (insurance, dividends, real estate transfers, and corporate dissolution) but maintain the same methodology for calculating income and gains. No doctrinal change is observed, but rather a uniform application of current regulations to diverse cases.
Analysis based on 52 of 53 rulings with a stated position. Updated 19 July 2026.