How the DGT's position has evolved
Current position
The homogeneity of a company's shares is maintained even if they are acquired in different European Union markets or in different currencies, as currency is an accessory aspect. In the context of AIE (International Economic Areas), negative tax bases are imputed to partners resident in Spain or with a permanent establishment in proportion to their economic rights and the provisions of the bylaws. Economic rights in pension plans only enjoy exemption if they meet the specific regulatory requirements of the TRL (Revised Text) of the Law on the Regulation of Pension Plans and Funds.
The DGT's position does not show a doctrinal evolution regarding a single concept, but rather addresses the nature of economic rights from different perspectives: taxation of AIE, pension plans, and the homogeneity of securities. No change in criterion is observed, but rather an application of specific rules to diverse scenarios. The doctrine remains stable in each area addressed.
Turning points
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Establishes that the difference in currency in the acquisition of shares in different EU markets does not alter their homogeneity as it is an accessory aspect.
Analysis based on 35 of 35 rulings with a stated position. Updated 23 September 2026.