How the DGT's position has evolved
Current position
The 30% reduction for irregular income requires compliance with the requirements of article 32.1 of the LIRPF (Personal Income Tax Law). It is not applicable to collective insurance benefits that instrument pension commitments, as article 18 of the LIRPF expressly excludes the income from article 17.2.a).5ª. In the case of arrears, the reduction applies if the generation period exceeds two years and no similar reductions have been applied in the previous five periods.
The DGT's position remains constant regarding the exclusion of collective insurance benefits from the reduction for irregular income. No doctrinal evolution is observed, but rather a reiteration of the exclusion based on article 18 of the LIRPF. Rulings regarding arrears and economic activities confirm the application of the general requirements of the regulation.
Analysis based on 30 of 32 rulings with a stated position. Updated 24 September 2026.