How the DGT's position has evolved
Current position
Income from movable capital includes dividends (in cash or in kind), yields from Treasury bills, and disability insurance benefits. Dividends in kind are valued at their market value and are included in the savings tax base. Insurance benefits are considered income through the difference between the capital received and the premium of the year. Commissions for active portfolio management, as well as lawyer or solicitor fees, are not deductible.
The DGT maintains a constant position on the nature of income, classifying various insurance benefits and dividends under this concept. No doctrinal change is observed, but rather an application of specific criteria for different assets, such as Treasury bills or dividends in kind. The doctrine is consistent in the exclusion of active management expenses and legal defense expenses.
Analysis based on 24 of 24 rulings with a stated position. Updated 24 July 2026.