How the DGT's position has evolved
Current position
The deductibility of expenses under the direct estimation method requires compliance with the principle of correlation with income. Expenses must be justified by an original or simplified invoice and recorded in the mandatory books. The link between the expense and the activity is a matter of fact that must be assessed by the management and inspection bodies.
The DGT's position remains constant regarding the requirements for the deductibility of expenses. The most recent rulings reiterate the need to prove the correlation with income and the correct documentary justification through invoices and accounting records.
Analysis based on 39 of 40 rulings with a stated position. Updated 21 August 2026.