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Practical Income Manual 2021.

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 that was generated prior to January 20, 2006 (the only one to which the reduction or reduction coefficients are applicable) must be distinguished from that generated later. to that date on 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 commented in this same Chapter and applying, where appropriate, the reducing coefficients that correspond in accordance with the provisions of the ninth Additional Provision of the Personal Income Tax Law .

In the case of subscription rights, the permanence period will be taken to correspond to the securities from which they come. When all subscription rights have not been transferred, it will be understood that those transferred corresponded to the securities acquired in the first place.