Deferred integration: Capital losses arising from transfers with repurchase of the transferred asset

The following capital losses will not be included for liquidation purposes in the same year in which they are generated; however, the loss must be declared and quantified in the declaration for the year in which it was generated.

1. Transfer of assets subsequently reacquired

   Losses arising from the transfer of assets will not be counted as capital losses when the transferor reacquires them within one year of the date of said transfer.

   This capital loss will be integrated when the subsequent transfer of the asset occurs.

2. Transfer of securities or shares and reacquisition of homogeneous securities

   Losses arising from the transfer of securities or shares will not be counted as capital losses when the taxpayer has acquired homogeneous securities within the following periods:

   1. If they are securities or shares admitted to trading on any of the official secondary securities markets defined in Directive 2004/39/EC of the European Parliament and of the Council of 21 April 2004 on markets in financial instruments, ( currently Directive 2014/65/EU) such as shares listed on the stock exchange, investment funds that comply with the daily reporting obligations established in the regulations that regulate IIC) when the taxpayer has acquired homogeneous securities within the two months before or after said transmissions.

   2. If these are securities or shares not admitted to trading on any of the official secondary securities markets defined in Directive 2004/39/EC of the European Parliament and of the Council of April 21, 2004 on markets in financial instruments, (currently Directive 2014/65/EU) such as SICAV and SOCIMI shares that are traded on the MAB, as the MAB is not one of the markets contemplated in that Directive, when the taxpayer has acquired homogeneous securities in the year before or after such transmissions.

   In these cases, capital losses will be integrated as the securities or shares that remain in the taxpayer's assets are transferred.

Reacquisition after the end of the declaration period (art.73.2 Rgl.)

When the taxpayer acquires the assets or homogeneous securities or shares after the end of the regulatory declaration period for the tax period in which the capital loss resulting from the transfer was calculated, he/she must submit self-assessment supplementary , including late payment interest, within the period between the date on which the acquisition takes place and the end of the regulatory declaration period corresponding to the tax period in which said acquisition is made. The late payment interest rate for the 2019 financial year is 3.75 percent.

Homogeneous values (art. 8 Rgl.)

For the exclusive purposes of this Tax, homogeneous securities or shares from the same issuer will be considered those that form part of a

same financial transaction or respond to a unity of purpose, including the systematic obtaining of financing, are of the same nature and transmission regime, and attribute to their holders substantially similar rights and obligations.

However, the homogeneity of a set of securities shall not be affected by any differences between them in relation to their unit value; dates of launch, material delivery or pricing; placement procedures, including the existence of tranches or blocks intended for specific categories of investors; or any other aspects of an accessory nature. In particular, homogeneity will not be altered by the division of the issue into successive tranches or by the provision of extensions.