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FIFO Method: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 8 rulings · 2014–2026

Current position

In the transfer of homogeneous securities, the FIFO (First-In, First-Out) method is applied to determine the age of the holdings. For fully bonus shares, the age corresponds to that of the pre-existing shares from which they originate. In the case of cryptocurrencies, the FIFO method is applied to partial sales of the same type of asset.

The DGT maintains the application of the FIFO method for homogeneous securities, specifying the treatment of bonus shares and capital increases. This position has recently been extended to cryptocurrencies, where the use of FIFO is required for partial sales of the same type of asset. The exception of using a different method due to errors in previous tax returns is not permitted.

Turning points

  1. V0191-16

    Establishes that the age of fully bonus shares is determined by the age of the last pre-existing share required to obtain them.

  2. V2034-24

    Clarifies that the FIFO method is not applicable to the sale of gold, as the regulations do not provide for special valuation methods for this asset.

  3. V0889-26

    Extends the application of the FIFO method to partial sales of the same type of cryptocurrency.

Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8
V0889-26 22 Apr 2026

Cryptocurrency sales taxed as capital gains, exempt from VAT

SG de Tributación de las Operaciones Financieras
criptoactivosganancias y pérdidas patrimonialesbienes inmaterialesrenta del ahorrométodo fifo LIRPF — Ley 35/2006 del IRPF art. 2LIRPF — Ley 35/2006 del IRPF art. 33.1
Affects CompanyExpat · Non-residentIndividual

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