How the DGT's position has evolved
Current position
Residents in Spain are taxed on their worldwide income and may apply the international double taxation deduction in accordance with article 80 of the LIRPF (Personal Income Tax Law). This deduction is applicable both when a treaty exists and when domestic regulations are applied in the absence of one. The foreign tax must be of an identical or analogous nature to the Spanish tax, and the deduction cannot exceed the portion of the Spanish tax corresponding to those incomes.
The DGT's position remains constant regarding the application of the international double taxation deduction. Throughout various rulings, the deductibility of foreign levies of an analogous nature, such as the Irish USC or European Parliament allowances, has been confirmed. No changes in criterion are observed, but rather a repeated application of domestic regulations and tax treaties.
Turning points
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Establishes that the Belgian 'précompte immobilier' is not deductible because it is a real estate tax and does not have an identical or analogous nature to income tax.
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Extends deductibility to levies that, although not expressly listed in the treaty, are of an identical or analogous nature, such as the Irish USC.
Analysis based on 37 of 40 rulings with a stated position. Updated 23 September 2026.