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V1676-24 10 July 2024 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

30% tax reduction not applicable to strategic plan bonuses if performance arises from Board resolution

An employee inquired whether an extraordinary bonus for meeting strategic plan objectives (2021-2023) qualifies for the 30% tax reduction. The DGT ruled it is not applicable because the performance arises from the Board's resolution and does not involve a generation period exceeding two years.

The question raised

Whether the 30 percent reduction provided for in Article 18.2 of the LIRPF is applicable.

The DGT's ruling

The 30% reduction under Article 18.2 of the LIRPF requires that the income has a generation period exceeding two years or is notably irregular. In this case, as it is a bonus approved by the Board of Directors, the income arises ex novo with said agreement. Therefore, it is not considered income with a generation period exceeding two years and the reduction is not applicable.

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