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V0629-22 24 March 2022 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos netos

30% reduction applicable to income generated over more than two years if not habitual

A technical architect inquired whether the 30% reduction could be applied to fees from a project lasting more than two years. The DGT ruled that this is possible provided that the acquisition of such income is not regular or habitual within their professional activity.

The question raised

Application of the 30% reduction under Article 32.1 of Law 35/2006.

The DGT's ruling

Net income with a generation period exceeding two years may be reduced by 30% if imputed to a single tax period. This reduction is not applicable if the income derives from an economic activity obtained on a regular or habitual basis. To determine regularity, attention must be paid to the nature of the income specific to each taxpayer and not to the general characteristics of their profession. If the case is an isolated and non-regular occurrence, the reduction is applicable.

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