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V1069-25 25 June 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Wages owed by court judgment must be attributed to the exercise in which the decision becomes final

A taxpayer asks about the tax treatment of unpaid wages (CPT and related items) recognised by judicial judgment. The DGT states these income must be attributed to the exercise in which the decision becomes final and examines the possibility of applying a reduction for irregularity.

The question raised

Taxation in Personal Income Tax (IRPF) of the arrears resulting from the judgment.

The DGT's ruling

Income from employment pending judicial resolution regarding its amount or entitlement must be attributed to the tax period in which the resolution becomes final. In this case, the attribution corresponds to the 2024 fiscal year. The 30% reduction for income with a generation period exceeding two years shall only be applicable if the arrears cover that time span and no similar reductions have been applied in the previous five periods.

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