How the DGT's position has evolved
Current position
Temporal accrual depends on the nature of the income: in the case of back pay for professional career progression or location allowances, it is accrued when the right arises or the resolution becomes final, allowing for the reduction under art. 18.2 of Law 35/2006 on Personal Income Tax (IRPF) if the generation period exceeds two years. Regarding unemployment benefits, enforceability is referred to the period of the original benefit. For capital gains, the key moment is the delivery of the assets, and in the corporate sphere, accounting accrual is followed according to the Law on Corporate Income Tax (LIS).
There is no single doctrinal evolution, as the rulings address different factual scenarios (employment income, capital gains, and corporate income). The DGT maintains specific criteria for each category: enforceability for back pay and benefits, delivery for assets, and accrual for companies. No change in trend is observed, but rather an application of accrual rules according to the type of income.
Analysis based on 64 of 71 rulings with a stated position. Updated 19 July 2026.