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Social Security contributions: 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

Doctrinal reversal Medium confidence 21 rulings · 2014–2026

Current position

Contributions paid under a Special Agreement with the Social Security system are considered deductible expenses from gross employment income. This is based on the fact that Article 19 of the LIRPF (Personal Income Tax Law) establishes that Social Security contributions are deductible expenses for determining net employment income.

The DGT's position has moved from considering that the employer's contributions under the special agreement have no tax impact for the worker, to recognizing their nature as a deductible expense. The evolution shows a shift towards the direct application of Article 19 of the LIRPF to allow the deduction of said contributions.

Turning points

  1. V2163-18

    Introduces the distinction that if the worker makes the payment of the contributions, they may indeed compute the deductible expense according to Article 19.2 a) of the LIRPF.

  2. V1516-26

    Establishes that the contributions under the Special Agreement are considered deductible expenses from gross employment income by mandate of Article 19 of the LIRPF.

Analysis based on 21 of 21 rulings with a stated position. Updated 25 September 2026.

Rulings on this topic

21

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