Doctrine by topic · DGT Observatory

Collection: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

← DGT Observatory

How the DGT's position has evolved

Refined position High confidence 15 rulings · 2014–2024

Current position

The non-seizability limit is determined based on the number of annual payments received by the debtor. If there are 17 payments, the monthly limit is calculated by dividing the annual SMI (Minimum Interprofessional Wage) by 17, doubling said amount in the months in which the extraordinary payment is received. If the salary already includes the pro-rata distribution of the payments, the limit is the annual SMI divided by 12 months.

The DGT's position on the application of non-seizability limits has evolved from an interpretation based on the accumulation of monthly perceptions (V3157-17) towards a precise mathematical calculation based on the number of annual payments (V0643-24). No change is observed regarding the responsibility of the payer, who must execute the seizures without assessing the legality of the tax action (V1572-14).

Turning points

  1. V3157-17

    Establishes that non-seizability limits must be applied to the totality of monthly perceptions, including the pro-rated portion of the extraordinary payment.

Analysis based on 15 of 15 rulings with a stated position. Updated 26 September 2026.

Rulings on this topic

15
V2290-15 20 Jul 2015

Amusement machine operators must record total takings as gross income

SG de Impuestos sobre las Personas Jurídicas
ingreso brutorecaudaciónbase imponiblemétodo de estimación directarealidad económica TRLIS — RDLeg 4/2004 (derogado por la Ley 27/2014) art. 10.3LIVA — Ley 37/1992 del IVA art. 4
Affects CompanyExpat · Non-residentIndividual
Email
Contact