How the DGT's position has evolved
Current position
The early payout of rights vested through ten years of seniority is taxed as income from employment, with the same treatment as pension plan benefits. If received as a lump sum, the 40% reduction applies to the portion of contributions made until December 31, 2006. In the event that the participant is already retired, the amount is considered a retirement benefit for the purposes of applying the reduction.
The DGT's position remains constant regarding the treatment of these amounts as income from employment and the application of the 40% reduction for contributions made prior to 2007. Recent rulings (V0231-25, V0390-25, V5164-26) confirm and reinforce the mechanics of seniority calculation and its coexistence with the retirement contingency.
Analysis based on 17 of 18 rulings with a stated position. Updated 25 September 2026.