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V0628-25 4 April 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · imputación temporal

Delays in professional career recognition are charged to the period of administrative resolution exigibility

A taxpayer asks how to temporarily assign career delays recognised in 2024 by a judicial ruling. The DGT responds that such delays must be assigned to the period when the administrative recognition decision becomes exigible.

The question raised

Temporal imputation and possible application of the reduction under art. 18.2 of the Personal Income Tax Law.

The DGT's ruling

The temporal imputation of back pay occurs in the tax period of the administrative resolution that recognizes the professional career level or grade, as this is when the right to receive them arises. If these earnings correspond to a generation period exceeding two years and are imputed in a single period, the 30% reduction under art. 18.2 LIRPF would be applicable, provided that similar reductions have not been applied in the previous five periods and they do not exceed 300,000 euros annually.

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