Doctrine by topic · DGT Observatory

Administrative Ruling: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Refined position High confidence 14 rulings · 2014–2025

Current position

Income from employment is imputed to the tax period in which it becomes due. Unless payments depend on a final judicial ruling, enforceability is determined by the administrative ruling that establishes the payment. If the amounts were due in previous years, the imputation must be carried out in the periods corresponding to those financial years.

The DGT maintains a consistent position on temporal imputation based on enforceability. The evolution shows a shift from enforceability linked to the moment of the administrative ruling toward enforceability linked to the moment when the right was effectively due, even if the ruling is subsequent.

Turning points

  1. V2598-25

    Specifies that if each amount was due in previous years, the imputation must be carried out in the periods corresponding to those financial years, regardless of the subsequent administrative ruling.

Analysis based on 14 of 14 rulings with a stated position. Updated 26 September 2026.

Rulings on this topic

14
V1888-14 14 Jul 2014

Salaries received in 2013 following a revoked sanction must be taxed in 2013

SG de Impuestos sobre la Renta de las Personas Físicas
rendimientos del trabajoimputación temporalexigibilidadperiodo impositivoresolución administrativa LIRPF — Ley 35/2006 del IRPF art. 14.2LGT — Ley 58/2003 General Tributaria art. 89.1
Affects CompanyExpat · Non-residentIndividual

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