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V2479-25 12 December 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · estimación objetiva

Objective estimation cannot be applied in 2026 if direct estimation was used in 2025

A taxpayer who used direct estimation in 2025 for a ceased activity asks whether objective estimation can be used in 2026 for a new activity. The DGT responds that it cannot, due to the three-year exclusion period.

The question raised

Whether the taxpayer can determine the net income of their new activity in 2026 in accordance with the objective estimation method under the Personal Income Tax (IRPF).

The DGT's ruling

The incompatibility between direct and objective estimation results in an exclusion from the objective method for the following three years. Since the incompatibility began in 2025, it remains in effect during 2025, 2026, and 2027. Therefore, in 2026, it is not possible to determine the net income of the new activity through objective estimation.

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