How the DGT's position has evolved
Current position
Social Security contributions made through a special agreement are considered deductible expenses from gross employment income. Their temporal allocation must be made in the tax period in which they become due, according to the chosen payment system (single payment or installments). This deductibility is independent of the training periods computed.
The DGT's position has moved from denying the status of self-employment or employment for certain deductions to confirming the deductibility of contributions as employment income expenses. The most recent rulings consolidate the treatment of these quotas as deductible expenses and specify their temporal allocation according to the payment system.
Turning points
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Establishes that contributions to the Special Agreement are considered deductible expenses when determining net employment income, as it is a situation assimilated to being registered.
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Specifies that the temporal allocation of contributions via special agreement for internships depends on the chosen payment system (single payment or installments).
Analysis based on 36 of 39 rulings with a stated position. Updated 17 September 2026.