How the DGT's position has evolved
Current position
The reduction limit for contributions to social security systems applies to the total set of all contracted instruments, preventing the limit from being increased by contracting various products. The mobilization of economic rights between systems is tax-neutral if the conditions of the pension plan regulations and the IRPF (Personal Income Tax) Regulations are met. The reduction regime of Article 51 of the LIRPF (Personal Income Tax Law) is not applicable to those who opt for the special regime of Article 93.
The DGT's position remains constant in its restrictive interpretation of reduction limits, confirming that it is not possible to multiply the caps by contracting multiple products (V1322-24). The doctrine has maintained the strict application of the requirements of Article 51.7 for the transfer of reductions to future fiscal years (V2590-14, V1501-19). No changes in criterion are observed, but rather a uniform application of the current regulations.
Turning points
-
Clarifies that the increase in the limit cannot be multiplied by making contributions to various social security instruments.
Analysis based on 28 of 28 rulings with a stated position. Updated 24 September 2026.