Transfer of shares or participations acquired before December 31, 1994

In this case, if a capital gain is obtained, the part of the capital gain generated before January 20, 2006 (the only one to which the reduction or abatement coefficients are applicable) must be distinguished from that generated after said date, to which the reduction or abatement coefficients are not applicable.

The determination of the capital gain generated prior to January 20, 2006 will be carried out in accordance with the special rule for these securities discussed in this same Chapter and applying, where appropriate, the reduction coefficients that correspond in accordance with the provisions of the ninth Additional Provision of the Income Tax Law

In the case of subscription rights, the duration period will be taken as that corresponding to the securities from which they originate. Where not all subscription rights have been transferred, it shall be deemed that those transferred correspond to the securities acquired first.