How the DGT's position has evolved
Current position
It is only possible to attach accrued credits whose maturity has not yet occurred or those involving successive payments through continuous or successive relationships. The attachment of future credits that have not yet arisen or whose existence is uncertain is unfeasible. The payer must withhold the amounts until the debt is covered and has a duty of cooperation to report on the emergence of new credits.
The DGT's position remains constant in the definition of attachable credits, limiting them to accrued or successive credits and excluding future ones. The doctrine has maintained the payer's duty of cooperation and the obligation to withhold in successive payments throughout the entire sequence.
Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.