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V1594-24 1 July 2024 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · imputación temporal

Income from employment received via court ruling is attributed to the tax year in which the judgment becomes final

A taxpayer inquired about when to declare amounts received in 2023 following a court ruling regarding extraordinary payments from previous years. The DGT ruled that these must be attributed to the period in which the judgment becomes final.

The question raised

Question raised: Temporal attribution of the amount collected.

The DGT's ruling

Income from employment, the amount of which depended on a judicial ruling, must be attributed to the tax period in which the judgment becomes final. If this income corresponds to a generation period exceeding two years and is attributed to a single fiscal year, it could be eligible for the 30 percent reduction under Article 18.2 of the LIRPF, provided that similar reductions have not been applied in the previous five periods and do not exceed 300,000 euros annually.

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