Doctrine by topic · DGT Observatory

Salary Differences: 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

Settled doctrine High confidence 13 rulings · 2016–2025

Current position

Income from employment pending judicial resolution regarding its amount or entitlement to receipt is imputed to the tax period in which the resolution becomes final. If the period in which such income was generated exceeds two years, the 30% reduction under article 18.2 of the LIRPF (Personal Income Tax Law) applies. This reduction is applied to the total amount of the income eligible for reduction.

The DGT's position remains constant regarding the imputation of salary differences to the fiscal year in which the judicial sentence becomes final. The evolution focuses on the application of the 30% reduction for generation periods exceeding two years, confirming its applicability according to rulings V0910-19 and V1173-25.

Turning points

  1. V0910-19

    Establishes that if the generation period of the income exceeds two years, the 30% reduction under article 18.2 of the LIRPF applies.

Analysis based on 11 of 13 rulings with a stated position. Updated 27 September 2026.

Rulings on this topic

13
V0242-25 5 Mar 2025

Salaries and late interest imputed to the year they became due

SG de Impuestos sobre la Renta de las Personas Físicas
imputación temporaldiferencias salarialesintereses de moraganancia patrimonialrendimientos del trabajo LIRPF — Ley 35/2006 del IRPF art. 14.1LIRPF — Ley 35/2006 del IRPF art. 14.2.a
Affects CompanyExpat · Non-residentIndividual

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