How the DGT's position has evolved
Current position
The temporal imputation of income is carried out in the tax period in which it becomes enforceable for the recipient. If the right depends on a judicial ruling, enforceability is determined when said ruling becomes final. In other cases, enforceability is established through the administrative resolution of granting or as agreed upon in the contract or agreement. If, due to causes not attributable to the taxpayer, they are received in a different period, they must be imputed to the financial year of their enforceability through a supplementary tax return.
The position of the DGT is constant throughout the analyzed corpus. The criterion remains that enforceability is the determining factor for temporal imputation, whether in income from employment, real estate capital, or joint accounts. No changes in doctrine are observed, but rather the application of the same principle to different factual scenarios.
Analysis based on 28 of 28 rulings with a stated position. Updated 22 July 2026.