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A professional consultant enquired whether the 30% reduction for income earned over a period exceeding two years could be applied. The DGT ruled that this is not possible because the fees were received across different tax periods.
Cuestión planteada Aplicación de la reducción del 30 por 100 del artículo 32.2 de la Ley 35/2006.
Para aplicar la reducción del 30% sobre rendimientos con un periodo de generación superior a dos años, es requisito indispensable que se imputen en un único periodo impositivo. En este caso, al haberse percibido parte del pago al inicio y otra al final del procedimiento, no se cumple dicho requisito de imputación única.
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