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V2426-20 15 July 2020 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos netos

30% reduction for irregular income cannot be applied if not imputed in a single period

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.

The question raised

Application of the 30 percent reduction under Article 32.2 of Law 35/2006.

The DGT's ruling

To apply the 30% reduction on income with a generation period exceeding two years, it is an indispensable requirement that it be imputed to a single tax period. In this case, as part of the payment was received at the beginning and another at the end of the procedure, said requirement of single imputation is not met.

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