Doctrine by topic · DGT Observatory

Redemption of Shares: 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 10 rulings · 2014–2025

Current position

Gains or losses from the redemption of shares in investment funds are determined by the difference between the acquisition value and the net asset value on the date of transfer. These income must be attributed to the tax year in which the change in assets occurs. In the case of persons with disabilities and protected assets, the ownership of the gains or losses corresponds to said person.

The DGT's position remains stable regarding the technical determination of the result and its temporal attribution. Rulings have addressed specific aspects such as the attribution of income under usufruct regimes, the management of compartments, the application of transitional regimes, and ownership in protected assets, without altering the general calculation rule.

Turning points

  1. V1636-14

    Establishes that in accumulating funds, the status of shareholder corresponds to the bare owner, who must compute the capital loss for the yield generated for the usufructuary.

  2. V1580-15

    Specifies that in compartment funds, the seniority rule applies only to the shares of the compartment being transferred.

  3. V1492-18

    Determines that gains or losses must be attributed to each co-owner in proportion to their share in the co-ownership.

Analysis based on 10 of 10 rulings with a stated position. Updated 28 September 2026.

Rulings on this topic

10
V1218-16 28 Mar 2016

Transfer value must be reported to apply the reduction for acquisitions prior to 1994

SG de Tributación de las Operaciones Financieras
reembolso de participacionesinstituciones de inversión colectivabase de retencióndisposición transitoria novenavalor de transmisión LIRPF — Ley 35/2006 del IRPF art. disposición transitoria novenaRIRPF — RD 439/2007, Reglamento del IRPF art. 97.1
Affects CompanyExpat · Non-residentIndividual

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