How the DGT's position has evolved
Current position
The acquisition of shares on own account to cover the risk of a derivative contracted with a client is exempt from tax. To apply this exemption, the entity must be a member of a trading venue and act habitually in market making. This criterion is based on Article 3.1.g) of Law 5/2020.
The sequence of rulings does not show a doctrinal evolution on a single concept, but rather addresses diverse matters such as dation in payment, tax groups, or deduction limits. There is no coherent evolutionary trajectory in the provided corpus to define a single criterion regarding a 'credit institution'.
Analysis based on 28 of 30 rulings with a stated position. Updated 24 September 2026.