How the DGT's position has evolved
Current position
Accrual is governed by accounting regulations and the enforceability of the obligation. Under Personal Income Tax (IRPF) via the direct estimation method, expenses are imputed when they occur in accordance with the matching principle. In successive performance operations, VAT (IVA) accrual occurs when the agreed portion of the price becomes enforceable according to the contract. For financing income, accrual follows the registration and valuation rules of the General Accounting Plan (PGC).
The sequence does not show a doctrinal evolution regarding a single concept, but rather applies the accrual principle to various matters (Wealth Tax, Inheritance and Gift Tax (ISD), IRPF, IVA, Property Tax (IBI)). The DGT maintains a constant application of accounting regulations and contractual enforceability to determine the timing of imputation in each case.
Analysis based on 22 of 25 rulings with a stated position. Updated 24 July 2026.