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V0256-19 7 February 2019 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimiento de trabajo

30% reduction applicable to incentives with a generation period exceeding two years

A company inquired whether an incentive based on a 2015 salary multiple, payable in 2019, qualified for the reduction under Article 18.2 of the LIRPF. The DGT ruled that it is applicable if the generation period exceeds two years and the income is imputed to a single tax period.

The question raised

Application of the 30 percent reduction referred to in Article 18.2 of the Tax Law to said incentive.

The DGT's ruling

The incentive is applicable to the 30% reduction if it has a generation period exceeding two years and is imputed in a single tax period. It cannot be classified as income notoriously irregular over time according to the IRPF Regulation. The application is conditional upon the taxpayer not having applied this reduction to other income with a generation period exceeding two years in the previous five tax periods. The quantitative limits established in Article 18.2 of the Law must be respected.

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