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V0473-26 2 March 2026 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · imputación temporal

Economic income must be attributed to the accounting period in which it is earned, not generated

A lawyer asks which accounting period income from services rendered between 2016 and 2018 should be attributed to, and whether the reduction for income generated more than two years ago can be applied. The DGT responds that income must be attributed to the period in which it is earned and that the mentioned reduction does not apply.

The question raised

Question posed: A consultation is made regarding which fiscal year the income corresponding to the aforementioned activity should be attributed to, and whether the reduction for income with a generation period exceeding two years would be applicable.

The DGT's ruling

As the cash basis of accounting has not been opted for, income must be attributed to the tax period in which it accrues in accordance with Corporate Tax regulations. The impairment loss on the credit must be reflected in the period in which the legal circumstances for such impairment occur. The 30% reduction for income with a generation period exceeding two years is not applicable because the activity does not span a period exceeding said term, nor is it classified as notoriously irregular.

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