How the DGT's position has evolved
Current position
The termination of the employment relationship by mutual agreement does not allow for the exemption under article 7 e) of the LIRPF (Personal Income Tax Law). To apply the 30% reduction for irregular income, it is an indispensable requirement that the amounts are imputed to a single tax period. If payment is split across different tax years, said reduction does not apply.
The DGT's position on the reduction for irregularity in the termination of employment relationships remains constant. Rulings V2686-16, V1978-21, and V1271-26 confirm that split payments prevent the application of the benefit under article 18.2 of the LIRPF. No doctrinal change is observed in this scenario.
Analysis based on 29 of 30 rulings with a stated position. Updated 24 September 2026.