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Contingencies: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Stable position Medium confidence 13 rulings · 2014–2025

Current position

Insurance premiums paid by the company on behalf of its employees are considered benefits in kind from employment income (IRPF). These must be valued at their amount or at the cost to the payer, and are integrated into the worker's taxable base. The tax treatment depends on whether the coverage is provided through social welfare mutual societies or private insurance.

The DGT's position does not show a single doctrinal evolution, but rather addresses the taxation of contingencies from different angles: the exemption in international transport, the deductibility of contributions to mutual societies, and the integration of insurance as benefits in kind. There is no change in criterion, but rather an application of the regulations according to the nature of the contingency and the subject.

Analysis based on 12 of 13 rulings with a stated position. Updated 27 September 2026.

Rulings on this topic

13
V2259-24 22 Oct 2024

Life annuities for retired directors are deductible in the period they are paid

SG de Impuestos sobre las Personas Jurídicas
pensión vitaliciaadministradorgasto deducibleretribución complementariacontingencias LIS — Ley 27/2014 del Impuesto sobre Sociedades art. 10.3LIS — Ley 27/2014 del Impuesto sobre Sociedades art. 11
Affects CompanyExpat · Non-residentIndividual

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