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V2099-25 6 November 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · imputación temporal

Wages differences are charged to the year when the judicial decision becomes final

A worker asks when a one-off payment of five years' wage differences following a judgment should be declared. The DGT responds that it is declared in the year the judgment becomes final and that a reduction for irregularity may apply if the generation period exceeds two years.

The question raised

Question posed: Temporal imputation of income received.

The DGT's ruling

Income from employment pending judicial resolution is imputed to the tax period in which the resolution becomes final. The 30 percent reduction for a generation period exceeding two years is applicable if the salary differences encompass said period, provided that similar reductions have not been applied in the five previous tax periods and do not exceed 300,000 euros annually.

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