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V3458-20 30 November 2020 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos netos

30% reduction not applicable to income with a generation period of less than two years

A lawyer consulted whether a 30% reduction could be applied to fees invoiced to a company after providing exclusive services to it. The DGT ruled that this is not applicable because the requirement that the generation period exceeds two years is not met.

The question raised

Application of the 30 percent reduction under Article 32.2 of Law 35/2006 to the fees invoiced by the taxpayer to the company in 2019, taking into account the work performed by the taxpayer individually for the client prior to providing legal services exclusively for the company.

The DGT's ruling

The 30% reduction applies to net income with a generation period exceeding two years or that which is notoriously irregular, subject to a limit of 300,000 euros. In this case, as the company was incorporated in 2018, the services rendered and invoiced in 2019 do not meet the required generation period of more than two years.

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