Specialties for change of residence to a country or territory considered a tax haven

When the change of residence occurs to a country or territory considered a tax haven and the taxpayer does not lose his status according to article 8.2 of the Income Tax Law specialties will apply:

1. Capital gains will imputed to the last tax period in which the taxpayer has his habitual residence in Spanish territory, and the market value of the shares or interests on the accrual date of said tax period will be taken into account for calculation.
2. In the event that shares or interests transferred in a tax period in which the taxpayer maintains such status, to calculate the capital gain or loss corresponding to the transfer the market value of the shares or interests that would have been taken into account to determine the capital gain provided for in this article will be taken as the acquisition value.