Doctrine by topic · DGT Observatory

Tax Option: 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 · 2022–2026

Current position

The reduction under Article 18.2 of the Personal Income Tax Law (LIRPF) is optional and constitutes a tax option. The taxpayer may file supplementary tax returns for previous years to remove improperly applied reductions and thus meet the requirements of the regulation. However, once the option has been exercised in the current tax year, the choice is irrevocable outside the statutory filing period.

The DGT's position remains constant regarding the nature of the reduction under Article 18.2 of the LIRPF as a tax option. Rulings confirm that it is possible to rectify previous years through supplementary returns to enable the reduction, but they maintain the irrevocability of the choice once the filing period for the current tax year has ended.

Analysis based on 6 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8

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