Doctrine by topic · DGT Observatory

Business Groups: 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 15 rulings · 2014–2026

Current position

The exemption for severance pay is limited to the mandatory amount under the Workers' Statute and is capped at 180,000 euros. In business groups acting as a single employer, the years of service provided within the entire group must be computed. The exemption does not apply to parts of the severance pay derived from commercial relationships.

The DGT's position remains constant regarding the computation of seniority in business groups. Since 2014, the administration has reiterated that, if the requirements to consider the group as a single employer are met, the years of service provided within it must be computed for the exemption. No changes are observed in this specific criterion throughout the sequence.

Analysis based on 15 of 15 rulings with a stated position. Updated 26 September 2026.

Rulings on this topic

15

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