How the DGT's position has evolved
Current position
Expenses under the direct estimation method are deductible if they comply with the principle of correlation with the income of the activity. They must be linked to the economic activity, have correct temporal imputation, be recorded in the accounting or mandatory books, and be justified by an original or simplified invoice. Verifying the link between the expense and the generation of income is a matter of fact that falls to the Tax Administration to determine.
The DGT's position has remained constant over time. Throughout the rulings, the need to prove correlation with income, documentary justification, and accounting records is systematically reiterated. No changes in substantive requirements are observed, but rather a repeated application of the same criterion to different types of expenses.
Analysis based on 55 of 58 rulings with a stated position. Updated 18 September 2026.