How the DGT's position has evolved
Current position
The 40% reduction of the transitional regime applies to lump-sum benefits corresponding to contributions made until December 31, 2006. For its application, more than two years must have elapsed since the first contribution and the benefit must be received within the period established by the twelfth transitional provision of the LIRPF (Personal Income Tax Law). If several benefits are received for the same contingency from the same plan, the reduction can only be applied to one of them.
The DGT's position remains constant regarding the application of the 40% reduction for contributions made prior to 2007. Recent rulings specify that, in the event of multiple redemptions for the same contingency, the right to the reduction is exhausted after its application to a single benefit. No change in criterion is observed, but rather a delimitation of its application in cases of multiple payments.
Turning points
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Establishes that if several benefits are received for the same contingency from the same plan, the reduction can only be applied to one of them.
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Reiterates that in redemptions derived from the same retirement contingency, the reduction can only be applied to one of the benefits.
Analysis based on 38 of 42 rulings with a stated position. Updated 19 July 2026.