How the DGT's position has evolved
Current position
Income from employment derived from judicial rulings is imputed to the tax year in which the ruling becomes final. The 30 percent reduction is applicable if the generation period exceeds two years and no similar reductions have been applied in the previous five tax periods. The application limit for the reduction is 300,000 euros per year.
The DGT's position remains stable regarding the requirements for the reduction for irregularity. The doctrine has moved from focusing exclusively on the installment payments of severance pay to integrating the imputation of income from final judicial rulings. Consistency is maintained in the calculation of the generation period and the amount limits.
Turning points
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Establishes that income pending judicial resolution is imputed to the period in which the ruling becomes final, differentiating the application of the reduction according to the nature of the income.
Analysis based on 36 of 43 rulings with a stated position. Updated 22 August 2026.