Doctrine by topic · DGT Observatory

Special Regime for Self-Employed Workers: DGT doctrinal evolution

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

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How the DGT's position has evolved

Settled doctrine High confidence 8 rulings · 2016–2024

Current position

The benefit for cessation of activity is considered income from employment, integrating both the benefit received and the contributions paid by the managing body. RETA (Special Regime for Self-Employed Workers) contributions are not deductible as an expense for income from employment, but must be applied as a deductible expense in the calculation of the net income from the economic activity. Subsidies to finance RETA contributions are classified as current subsidies and are imputed to the period of their accrual or collection according to the accounting method.

The DGT's position remains stable regarding the classification of benefits for cessation of activity as income from employment and the nature of RETA subsidies as current subsidies. A technical precision is observed in more recent rulings regarding the integration of contributions into the gross income and the correct deduction of contributions within the economic activity.

Turning points

  1. V2518-22

    Establishes the treatment of provisionally paid contributions, indicating that subsequent regularization acts as a higher expense or higher income depending on the result.

  2. V2281-23

    Determines that if a company assumes the contributions of the partner-worker, these constitute a benefit in kind, although they maintain their character as a deductible expense for the partner.

Analysis based on 7 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8
V1668-21 31 May 2021

Flat-rate RETA subsidy is taxable as income from economic activity for IRPF purposes

SG de Impuestos sobre la Renta de las Personas Físicas
rendimientos de actividades económicassubvenciones corrientesimputación temporalcriterio de devengocriterio de cobros y pagos LIRPF — Ley 35/2006 del IRPF art. 14.1.bLIRPF — Ley 35/2006 del IRPF art. 27.1
Affects CompanyExpat · Non-residentIndividual

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