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V1467-17 8 June 2017 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Economic improvements via employment subrogation must be taxed in the year the payment becomes due

A query was raised regarding when employees should declare a lump-sum payment received as an economic improvement following employment subrogation and a transfer of the workplace. The DGT has determined that this amount constitutes employment income and must be attributed to the year in which the worker is entitled to claim the payment.

The question raised

Given that the subrogation and transfer of the place of work occurred in 2017, the question concerns the temporal imputation of the amount corresponding to the aforementioned economic improvement.

The DGT's ruling

The economic improvement constitutes income from employment pursuant to Article 17.1 of Law 35/2006. The temporal imputation is made in the tax period in which the income becomes due to its recipient. In this case, the due date occurs upon subrogation and the transfer to the new place of work, carried out in 2017.

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