How the DGT's position has evolved
Current position
Compensation for personal injury under civil liability, with an amount judicially recognized, constitutes exempt income, including compensatory interest for delay in payment. Loss of earnings is not considered personal injury and must be taxed as employment income. Regarding per diems, the exemption for workers without an employment relationship, such as arbitrators, requires that the entity directly provides means of transport and accommodation.
The DGT's position does not show a single doctrinal evolution, as the rulings address entirely different exemption scenarios (shareholdings, international organizations, compensation, or per diems). There is no change in criterion regarding a single concept, but rather an application of the rule to diverse cases.
Turning points
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Extends the exemption for personal injury compensation to include compensatory interest for the delay in the payment of said amount.
Analysis based on 32 of 39 rulings with a stated position. Updated 18 August 2026.