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A Civil Guard officer inquired whether the 30% reduction under Article 18.2 of the Personal Income Tax Law (LIRPF) could be applied to 2022 payments consisting of structural productivity arrears from 2017 to 2021. The Directorate General for Taxes (DGT) ruled that it is applicable provided all legal requirements are met.
Question posed: Given that the differences were received in 2022 in a single payment with interest, it is asked whether the 30 percent reduction of Article 18.2 of Law 35/2006 is applicable.
Retributive arrears must be attributed to the tax period in which they become due, which in this case is 2022 due to the administrative resolution. If these earnings correspond to a generation period exceeding two years and are attributed to a single period, the 30% reduction is applicable. To this end, similar reductions must not have been applied to other earnings with a generation period exceeding two years in the previous five tax periods, and the amount must not exceed 300,000 euros annually.
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