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V0124-24 15 February 2024 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

30% reduction for income with generation period or irregularity is not applicable

An executive enquired whether an amount received following the modification of a variable remuneration scheme could benefit from the 30% reduction under Article 18.2 of the IRPF Act. The DGT has ruled that it is not applicable because there is no generation period and it does not fall under the category of notoriously irregular income.

The question raised

Whether the 30 percent reduction provided for in Article 18.2 of the LIRPF is applicable.

The DGT's ruling

The 30% reduction is not applicable because the amount received is a certain sum that arises ex novo and is not linked to a generation period. Furthermore, it does not qualify as notoriously irregular income, as the amount does not constitute the substitution or repair of a salary supplement of indefinite duration. Therefore, the requirements of Article 18.2 of the LIRPF and the regulation are not met.

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