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V1351-24 7 June 2024 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

30% reduction for irregular income cannot be applied if payment is not attributed to a single tax period

A worker inquired whether the compensation from an early retirement agreement could benefit from the reduction for irregular income. The DGT ruled that it is not applicable because the agreement involves monthly payments spanning several tax periods.

The question raised

Consideration of the severance payment as income from employment obtained in a notoriously irregular manner over time and the consequent application of the reduction provided in Article 18.2 of Law 35/2006.

The DGT's ruling

The 30% reduction for income obtained in a notoriously irregular manner requires that such income be imputed to a single tax period. Although amounts resulting from the mutual agreement termination of an employment relationship are regulationally classified as irregular, if the agreement includes monthly payments distributed across different fiscal years, the requirement of single imputation is not met and the reduction is not applicable.

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