How the DGT's position has evolved
Current position
Severance payments for collective redundancies are exempt up to the limit of unfair dismissal and a maximum of 180,000 euros, with any excess taxed as employment income. Carried interest is classified as employment income due to the granting of rights during the course of activity, allowing for 50% integration if payment occurs after termination. Public birth grants are exempt pursuant to article 7 h) of the LIRPF (Personal Income Tax Law).
The DGT's position is heterogeneous due to the diversity of cases treated, without a single evolutionary trend. Consistency is maintained in the treatment of severance payments for collective redundancies, and the nature of carried interest has been clarified regarding the termination of office.
Turning points
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Clarifies that the classification of carried interest as employment income is not altered by subsequent termination, allowing for 50% integration if the rights were granted during the course of activity.
Analysis based on 32 of 41 rulings with a stated position. Updated 17 August 2026.