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V1429-25 29 July 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Extraordinary restructuring aid taxed as income from work

The DGT confirms that aid under Royal Decree 908/2013 for workers affected by corporate restructuring is treated as income from work and is subject to taxation without exemption.

The question raised

Taxation of aid granted under the provisions of Article 4.2 of Royal Decree 908/2013, of November 22, which establishes special rules for the granting of extraordinary aid to workers affected by corporate restructuring processes, in the event that the company has not paid the statutory severance pay.

The DGT's ruling

Extraordinary aid for workers affected by corporate restructuring processes is classified as employment income, as it derives from the employment relationship. It is not covered by any exemption provision and its temporal imputation is made in the period in which it becomes due, following the recognition of the right to its granting. Likewise, the reduction provided for in Article 18.2 of the Personal Income Tax Law (LIRPF) cannot be applied as the requirements regarding the generation period or the provisions of the Regulations are not met.

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