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V2545-18 18 September 2018 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos de actividades económicas

Income from instalment-based economic activities is recognised based on the collectability of payments

A lawyer asks how to temporally recognise fees for a judicial administration that will be collected in three years. The DGT rules that, as the cash basis of accounting has not been chosen, the Corporate Tax rules for instalment transactions apply.

The question raised

Question raised 1) Temporal allocation of the aforementioned income.

The DGT's ruling

For installment operations or those with deferred pricing, income is understood to be obtained proportionally as payments become due, unless the accrual basis is chosen. In this case, as neither the cash basis nor the accrual basis has been chosen, the allocation must be made in the periods in which the payments are due (2018, 2019 and 2020). The 30% reduction for irregular income is not applicable as it is not allocated to a single tax period.

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