3.1. Period of permanence of the asset element in the taxpayer's assets prior to December 31, 1996.

The period of permanence in the taxpayer's assets prior to December 31, 1996 of the asset element is calculated.

For these purposes, the number of years, rounded by excess, between the date of acquisition (which must be prior to December 31, 1994) and December 31, 1994, will be taken as the period of permanence in the taxpayer's assets. nineteen ninety six. According to this rule, one year and one day will constitute two years; two years and one day will constitute three years, and so on.

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.

If improvements have been made to the assets transferred, the period of permanence of these in the taxpayer's assets will be taken as the number of years between the date on which they were made and December 31, 1996, rounded by excess.