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Doctrine by topic · DGT Observatory

Policyholder: 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

Settled doctrine High confidence 18 rulings · 2016–2026

Current position

For health insurance premiums to constitute an exempt benefit in kind, the company must be the policyholder and the provision must be agreed upon in the contract or collective agreement. If the company only acts as a payment intermediary so that the employee may acquire the service, it is considered monetary income without exemption. Under the direct estimation regime, premiums are only deductible if the taxpayer themselves is the policyholder.

The DGT's position remains constant regarding the distinction between the figure of the policyholder and payment mediation. It has been reiterated that the exemption for benefits in kind requires the company to be the policyholder and not a mere payment intermediary. Likewise, deductibility under direct estimation requires that the taxpayer holds the status of policyholder.

Analysis based on 17 of 18 rulings with a stated position. Updated 25 September 2026.

Rulings on this topic

18

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