126.96.36.199. Unjustified capital gains
Assets or rights whose possession, declaration or acquisition does not correspond to the income or assets declared by the taxpayer will be considered unjustified capital gains, as well as the inclusion of non-existent debts in any declaration for this Tax or for the Tax on the Heritage, or its registration in official books or records.
Unjustified capital gains will be integrated into the general taxable base of the tax period in respect of which they are discovered, unless the taxpayer sufficiently proves that he has been the owner of the corresponding assets or rights from a date prior to the limitation period.
Unjustified capital gains will be attributed based on the ownership of the assets or rights in which they are manifested (art. 11.5 Law).