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V1365-25 21 July 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · imputación temporal

Earnings are attributed to the period when due, not when received

A taxpayer asks whether a payment received in January 2025 for a course delivered in 2024 should be declared in 2024 or 2025. The DGT states that attribution depends on the due date under existing agreements.

The question raised

In which tax period must the income obtained and the withholding tax applied be declared.

The DGT's ruling

The temporal imputation of income from employment is carried out in the period in which it becomes due to the recipient. If, due to circumstances not attributable to the taxpayer, it is received in a period different from that in which it was due, it shall be imputed to the period in which it was due. The withholding tax must be imputed to the same period to which the income is imputed, regardless of when it was applied.

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