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V1119-20 28 April 2020 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · imputación temporal

Employment income is attributed to the tax year in which it becomes due, in this case 2019

A query was raised regarding whether arrears for the professional career supplement corresponding to 2017 and 2018 should be attributed to those years or to the year they were paid. The DGT ruled that they must be attributed to the tax year in which they become due, which is 2019.

The question raised

Question raised: Temporal attribution.

The DGT's ruling

Income from employment is attributed to the tax period in which it becomes due for the recipient, pursuant to Article 14.1, a) of Law 35/2006. As enforceability occurred in 2019 due to the approval of the regulations allowing its recognition, the income must be attributed to said fiscal year. These are not considered arrears that must be attributed to previous fiscal years.

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