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The DGT states that a commission paid over three years is not eligible for the 30% reduction under Article 18.2 of the LIRPF as the right to earnings arises from the December 2024 agreement, not from the passage of time.
Question posed: Application of the 30 percent reduction provided in Article 18.2 of the Personal Income Tax Law to the aforementioned extraordinary remuneration.
The 30% reduction is not applicable because there is no generation period exceeding two years. The income is not linked to the passage of a period of time exceeding that number of years, but rather arises ex-novo with the agreement that recognizes the right to the extraordinary remuneration. It also does not qualify as income obtained in a notoriously irregular manner over time.
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