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V2202-25 17 November 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

2023 salaries paid by FOGASA to be attributed to 2023 via supplementary self-assessment

A worker asks which year salaries from 2023, paid through FOGASA following a judicial decision, should be attributed to. Tax authorities state that 2023 salaries belong to that year, while tramitación salaries belong to the year when the judicial decision becomes final.

The question raised

For the purposes of the Personal Income Tax return, to which year should these received amounts be imputed.

The DGT's ruling

Employment income is imputed to the period in which it becomes due. When, due to circumstances not attributable to the taxpayer, it is received in different periods, it is imputed to the fiscal year in which it was due through a supplementary self-assessment without penalties or interest. Salaries from 2023 must be imputed to 2023, whereas processing salaries are imputed to the period in which the judicial resolution establishing them became final (2025).

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