3.1. Period of permanence of the asset element in the taxpayer's assets prior to December 31, 1996.
The period of time that the asset remained in the taxpayer's assets prior to December 31, 1996 is calculated.
For these purposes, the period of permanence in the taxpayer's assets will be taken as the number of years, rounded up, between the date of acquisition (which must be before December 31, 1994) and December 31, 1996. According to this rule, one year and one day will constitute two years; Two years and one day will make three years, and so on.
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.
If improvements have been made to the transferred assets, the period of time that these remain 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 up.