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V1413-20 14 May 2020 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · estimación objetiva

Objective estimation may be applied to income attribution entities and individual direct estimation

A taxpayer inquired whether it is possible to use objective estimation for an agricultural activity within an income attribution entity while simultaneously using direct estimation for their individual gardening activity. The DGT ruled that there is no incompatibility between these two methods.

The question raised

Whether there is an incompatibility between the methods of determining yields that the applicant intends to use.

The DGT's ruling

The application of the objective estimation method to entities under the income attribution regime must be carried out regardless of the circumstances of their partners. There is no incompatibility for the entity to use objective estimation and the partner to use direct estimation in a different activity, as there are no identical or similar activities nor common management.

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