Doctrine by topic · DGT Observatory

Gross Amount: 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 8 rulings · 2014–2026

Current position

Income obtained in Spain, whether through professional services, artists' income, or special regimes, must be computed by its gross amount. It is not possible to reduce the taxable base for concepts such as social security contributions or expenses, even if they appear itemized. Withholding tax must be applied to the total amount of the sums received.

The DGT maintains a consistent position in which the concept of gross amount prevents the deduction of expenses or social security contributions to determine the taxable base. Throughout the rulings, this criterion has been applied transversally to dividends, severance payments, maternity deductions, non-resident income, and professional services.

Analysis based on 7 of 8 rulings with a stated position. Updated 30 September 2026.

Rulings on this topic

8
V2207-25 17 Nov 2025

Property income under displaced workers regime declared at full amount

SG de Impuestos sobre la Renta de las Personas Físicas
régimen especial de desplazadosrendimientos de capital inmobiliarioimporte íntegrodeducción de gastosresidencia fiscal LIRPF — Ley 35/2006 del IRPF art. 93LIRPF — Ley 35/2006 del IRPF art. 93.2
Affects CompanyExpat · Non-residentIndividual

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