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V0892-25 23 May 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · estimación objetiva

The application of objective estimation depends on the cause of the current situation and compliance with exclusion or renunciation deadlines

A taxpayer using direct estimation for courier services wishes to start a new transport activity and apply the objective estimation method. The DGT states it cannot assess without knowing whether the current situation results from a renunciation or exclusion, and when it occurred.

The question raised

Question posed: Whether the taxpayer can determine the net income of her new activity in accordance with the objective estimation method, taking into account that she meets the general requirements corresponding to the volume of income and the number of assets assigned, and also taking into account that she would maintain the commercial relationship she had with the main client of the courier and parcel delivery activity.

The DGT's ruling

The possibility of applying the objective estimation method depends on whether the incompatibility with the direct estimation method persists at the commencement of the new activity. If the cause was an exclusion, it must be verified whether the three-year mandatory period in the direct estimation method has elapsed. If the cause was a renunciation, this has a minimum effect of three years and must be expressly revoked to return to the objective method. Both consulted activities fall within the scope of application of the objective estimation method for 2025.

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