The 2025 Spanish IRPF campaign opened on 8 April 2026 and closes on 30 June. Anyone who had more than one employer during 2025, drew SEPE unemployment benefit, received a Social Security pension while also earning a salary, or any other combination involving a second withholding stream, falls under the differentiated filing-obligation rules of Article 96 LIRPF. This piece sets out the mechanics with the figures in force and the cases we see every campaign.
Statutory basis: Article 96 LIRPF
Article 96 of Law 35/2006 (LIRPF) sets out the obligation-to-file thresholds for employment income. Structure for 2025:
- Single payer — threshold of €22,000 gross per year.
- Two or more payers with second-and-further payer total above €1,500 — threshold of €15,876 gross per year.
- Two or more payers with second-and-further payer total at or below €1,500 — threshold of €22,000 gross per year (single-payer rule applies).
- Non-exempt compensatory pensions or alimony — no threshold; obligation to file is automatic.
Who counts as a second payer
The technical concept of "payer" is not limited to a second employer. DGT doctrine and AEAT criteria treat the following withholding sources as second payers:
- SEPE — when contributory unemployment benefit is collected concurrently with employment income within the year. SEPE typically withholds at 0% or a very low rate.
- FOGASA — payments by the wage guarantee fund in employer insolvency receive withholding from a payer other than the original employer.
- Social Security — retirement, disability, widowhood or orphan's pensions concurrent with salary, another pension or any employment income.
- Mutuals and pension plans — benefits drawn by mutualists or plan participants taxed as employment income at the time of redemption.
- Foreign employer with Spanish withholding — non-resident payer applying withholding on employment income under the relevant double-taxation treaty.
The under-withholding effect
Article 80 RIRPF governs how each payer computes the withholding rate. The calculation is based on the annual base of employment income from that payer alone, not on the taxpayer's total income. The consequence is structural: two payers withholding 13% each on income totalling €30,000 produce an aggregate withholding lower than the rate that would correspond to the taxpayer's marginal rate (around 24%–30% on €30,000). The standard file reaches us this way: draft owing between €600 and €2,500 with no errors anywhere — it is simply how the system is built.
The taxpayer can mitigate the effect for the following year by asking the principal payer to apply a voluntary withholding rate above the legal minimum via Form 145. The action does not affect the current return but eases the adjustment in the next campaign.
Typical 2025 cases
ERTE or SEPE benefit during 2025
Anyone who collected an ERTE or contributory unemployment benefit in some part of 2025 and kept or resumed employment activity in another part has the SEPE as a second payer. SEPE withholding on benefits below €14,000 is usually 0%. If the aggregate exceeds €15,876, the obligation to file is triggered. The return typically comes out owing tax.
Change of employer in 2025
Anyone who changed employer during 2025 accumulates two payers. Even if the transition was clean and without overlap, the withholding calculation done by each company at the start of its respective period was based on a partial annual projection. Aggregate annual withholding falls short if the second employer did not estimate the first payer's income correctly (the taxpayer either submitted Form 145 with overstated remaining income, or did not submit it at all).
Pension + salary
Persons collecting a Social Security retirement or disability pension and earning employment income from compatible activity are by definition multi-payer cases. The Social Security applies withholding using the data it holds (declared pension and historical contribution bases) without knowledge of the current salary. The return almost always comes out owing tax and the obligation to file is the norm.
Concurrent part-time employment
Working part-time for two or more employers simultaneously activates the second-payer regime from the start of the year. Each employer withholds on the part it pays, with no information about the other. Submitting Form 145 to the principal employer with full projected income is advisable so the rate is calibrated correctly from the first month.
When there is an obligation but the return shows a refund
A taxpayer with two payers whose aggregate income exceeds €15,876 must file even if the result is a refund. The obligation is independent of the sign of the liability. Failure to file gives rise to a tax-procedure infringement under Article 198 LGT (minimum sanction €200 for non-filing) and, where the AEAT detects it, a subsequent enforcement action.
When there is no obligation but filing makes sense
A taxpayer with two payers whose aggregate income does not exceed €15,876 has no obligation to file. Filing nonetheless can be worthwhile if:
- Regional rent, energy-efficiency or large-family deductions trigger a refund.
- There are capital losses for the year worth declaring so they can be offset over the next four (Article 49 LIRPF).
- The proposed draft shows a refund due to over-withholding by the first payer.
- There are pension-plan contributions reducing the taxable base.
Instalment payment
Where the return shows tax owing, Article 62.2 LGT and Article 80 LIRPF allow payment to be split into two interest-free instalments without guarantee: 60% on filing and 40% in November. The second instalment is direct-debited. The instalment plan does not require justification and is requested at the time of filing.
Our position
We work files with two payers using a fixed sequence. First we verify the aggregate employment income crosses the Article 96 LIRPF threshold and that the filing duty is therefore active. Then we reconstruct effective aggregate withholding and compare it with the projected liability; the gap anticipates the result. We apply the regional deductions the draft omits. If the result is owed tax, we recommend the standard 60/40 instalment plan. And we leave a Form 145 ready for the client to submit to the principal payer in January of the following year, preventing the situation from recurring next campaign.