How the DGT's position has evolved
Current position
Employment income is imputed according to its enforceability for the recipient. To apply the 30% reduction for notoriously irregular income, it is an indispensable requirement that such amounts are imputed in a single tax period. In cases of employment termination by mutual agreement with installment payments, this requirement of single imputation is not met.
The DGT maintains a consistent stance on the imputation of income based on enforceability. It has been specified that the reduction for irregularity requires imputation in a single fiscal year, ruling out this benefit in termination agreements that provide for monthly payments until retirement.
Turning points
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Specifies that a mutual agreement pact with monthly payments until retirement prevents the single imputation necessary for the 30% reduction.
Analysis based on 29 of 30 rulings with a stated position. Updated 24 September 2026.