How the DGT's position has evolved
Current position
Income is imputed to the tax period in which it becomes due for the recipient. In the case of employment income, due date is determined according to usage, customs, or agreements, which may shift the imputation to the following fiscal year if the right to collection arises after December 31. If effective receipt differs from the due date due to causes beyond the taxpayer's control, the due date period prevails. Withholding tax must be imputed to the same period as the income.
The DGT maintains a constant position based on the principle of due date for the determination of the tax period. Recent rulings reinforce this criterion by applying it specifically to insurance, employment income, and the synchronization of withholding tax with income. No changes in doctrine are observed, but rather a technical application of the concept of due date to different types of income.
Analysis based on 55 of 58 rulings with a stated position. Updated 13 August 2026.