How the DGT's position has evolved
Current position
The 30% reduction under Article 18.2 of Law 35/2006 on Personal Income Tax (IRPF) requires that the earnings have a generation period exceeding two years and are imputed to a single tax period. It is not applicable if the earnings derive from an economic activity where they are obtained regularly or habitually. In the case of unfair dismissal compensation, the amount exceeding the exempt limits may benefit from this reduction if the requirements regarding timing and amount are met.
The DGT has maintained a consistent line regarding the definition of the generation period, clarifying that it is determined by the time of production of the earnings and not by the time elapsed until their collection. It has been specified that the reduction requires imputation to a single period and is excluded when the income is habitual due to economic activity. The doctrine has been consolidated through the application of these requirements to various concepts such as back pay, copyrights, or bonuses.
Turning points
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Defines that the generation period is determined by the time in which the earnings were produced and not by the time from their accrual until their collection.
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Establishes that the reduction is not applicable if the earnings derive from an economic activity where they are obtained regularly or habitually.
Analysis based on 27 of 29 rulings with a stated position. Updated 27 July 2026.