Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The volume of income for objective estimation is assessed independently for each taxpayer. Joint computation only proceeds if two requirements are met: that the activities are identical or similar (same IAE group) and that there is a common management sharing personal or material resources. In this case, the income of the taxpayer, spouse, ascendants, descendants, and entities under the income attribution regime must be summed.
The DGT's position remains constant at its core. The evolution shows an expansion of the scope of joint computation, moving from focusing solely on the spouse (V0261-15) to explicitly including ascendants, descendants, and entities under the income attribution regime (V1725-20, V0427-22, V2645-22).
Turning points
Expands the subject of joint computation to include not only the spouse, but also descendants, ascendants, and entities under the income attribution regime.
Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.