Considerations derived from the transmission, reimbursement, amortization, exchange or conversion of any type of financial assets, regardless of the nature of the performance they produce, implicit, explicit or mixed

Negotiable securities representing the raising and use of external capital are considered financial assets, regardless of the way in which they are documented. This consideration is also given to negotiable instruments, including those originating from commercial operations, from the moment they are endorsed or transferred, unless the endorsement or transfer is made as payment for a credit from suppliers or providers. Financial assets include, among others, the following securities:

• Public Debt Securities (Treasury Bills, Obligations and Government Bonds).
• Financial letters.
• Financial or corporate promissory notes issued at a discount.
• Obligations or bonds with periodic accrual of coupons or with issue, amortization or reimbursement premiums.
• In general, any asset issued at a discount.

Article 91 of the Personal Income Tax Regulations distinguishes between financial assets with implicit returns, with explicit returns and with mixed returns, for the purposes of subjecting these returns to the withholding or advance payment system, without said distinction having any relevance in the tax classification of the returns obtained.

Financial assets with implicit yield are considered those in which the yield is generated by the difference between the amount paid in the issue, first placement or endorsement and the amount committed to be reimbursed at the maturity of the operation. The implicit returns include issue, amortization or reimbursement premiums.

Financial assets with explicit yield are considered those that generate interest and any other form of remuneration agreed upon as consideration for the transfer of own capital to third parties and are not included in the concept of implicit yield in the terms discussed in the previous paragraph.

financial assets with mixed returns are those that generate implicit and explicit returns. These securities will follow the regime of financial assets with explicit yield when the annual cash they produce of this nature is equal to or greater than the reference rate in force at the time of issue, even if another additional yield has been implicitly established in the conditions of issue, amortization or reimbursement. They will follow the regime of financial assets with implicit returns when the annual cash is lower than the reference.

Important: All returns derived from operations carried out on financial assets generate, without exception, returns on movable capital. However, in the case of lucrative transfers of financial assets due to the death of the taxpayer (the so-called "capital gains of the deceased"), it will be deemed that there is no return on movable capital. Since January 1, 2015, the negative capital gains derived from the profitable transfer of capital by "inter vivos" acts are not computed (Art. 25.6 Law IRPF ).