How the DGT's position has evolved
Current position
The rectification of self-assessments is appropriate when events occur that affect the taxable base of previous tax years, such as the reimbursement of excess income received or the lack of equivalence in compensation. The Administration must assess the sufficiency of the evidence provided to validate these changes. In cases of contractual breach, the loss of assets must be imputed in the tax year in which the ownership of the money is lost.
The DGT's position remains constant regarding the need to rectify the corresponding tax years when the taxable event occurs in them, regardless of when the financial movement takes place. No doctrinal change is observed, but rather an application of the temporal imputation criterion in various scenarios such as Social Security refunds, late payment interest, or compensation.
Analysis based on 71 of 74 rulings with a stated position. Updated 18 September 2026.