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V3277-23 21 December 2023 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · estimación directa

Deductibility of master's degree costs depends on correlation with business income

A self-employed lawyer inquired whether the cost of a master's degree in taxation could be deducted as a training expense. The DGT indicates that deductibility is conditional upon proving the correlation between the expense and the income generated by the activity.

The question raised

To determine the deductibility of the cost of the aforementioned official master's degree as training expenses, for the purpose of determining the net yield of the economic activity carried out.

The DGT's ruling

The deductibility of expenses is subject to the principle of correlation with income, and it must be proven that they were incurred in the course of the activity. The verification of said correlation is a matter of fact that falls under the responsibility of the management and inspection bodies. Furthermore, the expense must be justified by an invoice and recorded in the mandatory books.

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