Table: delivery of shares free of charge or at a price below the normal market price by the company to its workers

Note: The following table analyzes the treatment in Personal Income Tax of:

The free delivery of company shares and participations to its workers.
Non-transferable stock options -suppose the granting by the company to its workers of a right of purchase option for a determined number of shares of the company, at an agreed price below the market and which may be exercised during a certain period, without said right of purchase option can be transmitted by the worker.

**Delivery of shares free of charge or at a price below the normal market price by the company to its workers**
Qualification	Personal income tax valuation	Tax benefits	Subject and non-exempt RT imputation
Work Income (RT) in kind Subject to deposit on account	*A. IN GENERAL* Free delivery accs Market value at the time of delivery. In the case of listed shares quotation value Non-transferable stock options Difference between the Market value/quotation value of the shares at the time of exercising the option – Price at which the option can be exercised (effective acquisition price).	*A. IN GENERAL* Exemption up to 12,000 euros per year Same conditions for all workers. With the required requirements of art. 42.3.f) Law Personal Income Tax . Reduction of 30% on the non-exempt amount if it had been generated in a period of more than 2 years and provided that in the previous 5 years no other amounts had been obtained RT to whom the reduction would have been applied (art. 18, paragraphs 1 and 3 Law Personal Income Tax ).	*A. IN GENERAL* Art. 14.1.a) Law Personal Income Tax . When RT is required. That is, when they are delivered. In the case of non-transferable inter vivos purchase options (non-transferable stock options), the RT will accrue at the time the beneficiary exercises his or her purchase option right. That is, also when shares are delivered. If the option is not exercised at any time, there will be no income of any kind to be attributed.
Work Income (RT) in kind Subject to deposit on account	*B. EMERGING COMPANIES (as of January 1, 2023)* Free delivery accs Difference between: If there is expansion : value of the shares subscribed by an independent 3 in the last capital increase carried out in the year prior to the year in which they are delivered. If there is no extension : market value at the time of delivery. Non-transferable stock options Same as delivery, discounting the price at which you can exercise the option.	B. EMERGING COMPANIES (as of January 1, 2023) Exemption up to 50,000 euros per year With the required requirements of art. 42.3.f) Law Personal Income Tax except that It is not necessary that the offer be made under the same conditions for all the company's workers, but it must be made within the company's general remuneration policy and that contributes to their participation in the company. Paragraph 2 of art. 42.3.f) Law Personal Income Tax Non-transferable stock options : To be eligible for the exemption, the condition of being an emerging company must be met at the time the option is granted. Not when the shares are exercised and delivered. Paragraph 2 of art. 42.3.f) Law Personal Income Tax . Reduction of 30% on the non-exempt amount if it had been generated in a period of more than 2 years and in the previous 5 years no other amounts had been obtained RT to whom the reduction would have been applied (art. 18, paragraphs 1 and 3 Law Personal Income Tax ).	EMERGING COMPANIES (as of January 1, 2023) Art. 14.2.m) Law Personal Income Tax . They are imputed and declared in the tax period in which any of the ss occurs. circumstances: The shares of the emerging company are admitted to trading in regulated markets. The shares come out of the taxpayer's assets. In any case, in the tax period in which the 10-year period from delivery occurs when the previous ones do not occur. Although the payments on account are made when they are delivered (in the case of non-transferable stock options when the purchase option is exercised) they will be allocated when the returns are declared. (art. 79 Regulation Personal Income Tax )