How the DGT's position has evolved
Current position
The receipt of subsidies constitutes, as a general rule, a capital gain that must be included in general income. However, the aid granted under Royal Decree 477/2021 is exempt from inclusion in the taxable base pursuant to the fifth additional provision of the LIRPF (Personal Income Tax Law). The temporal allocation of non-exempt capital gains is made in the period in which the payment is received.
The DGT maintains the doctrine that subsidies are capital gains includable in general income. This position has undergone a partial reversal regarding self-consumption and renewable energy aid, due to the application of the fifth additional provision of the LIRPF, which establishes their non-inclusion.
Turning points
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Introduces the exception to the general rule, stating that the aid from Royal Decree 477/2021 is not included in the taxable base by mandate of the fifth additional provision of the LIRPF.
Analysis based on 59 of 61 rulings with a stated position. Updated 18 September 2026.