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Indirect formulas: 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

Refined position High confidence 12 rulings · 2015–2025

Current position

Indirect meal voucher formulas, such as vouchers or electronic cards, are exempt from IRPF (Personal Income Tax) provided the amount does not exceed 11 euros per day. The instruments must be nominative, non-transferable, and non-reimbursable. The service must be provided on business days and must not coincide with days on which the worker earns exempt meal allowances.

The DGT's position has maintained the structure of the exemption but has increased the exemption limit from 9 to 11 euros per day according to ruling V1899-18. Likewise, it has been specified that the exemption for restaurant tickets does not count towards the progressivity of the average tax rate, according to V2542-25.

Turning points

  1. V1899-18

    Increases the exemption limit for indirect formulas, establishing that the amount must not exceed 11 euros per day.

  2. V2542-25

    Clarifies that this exempt income is not considered exempt income with progressivity for the calculation of the average tax rate.

Analysis based on 11 of 12 rulings with a stated position. Updated 27 September 2026.

Rulings on this topic

12
V2046-23 13 Jul 2023

Cash payments for food count as cash income; meal vouchers may be exempt

SG de Impuestos sobre la Renta de las Personas Físicas
rentas en especierendimientos del trabajofórmulas indirectasvales-comidaexención LIRPF — Ley 35/2006 del IRPF art. 17.1LIRPF — Ley 35/2006 del IRPF art. 42.1
Affects CompanyExpat · Non-residentIndividual

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