How the DGT's position has evolved
Current position
Taxpayers performing taxable and non-exempt activities must submit quarterly tax returns using Form 303 and an annual summary return using Form 390. The obligation to file tax returns does not affect those performing exclusively exempt operations, who must use Form 309. The right to deduction may be exercised in the period in which the amounts are incurred or in subsequent periods within the four-year period.
The DGT's position remains stable regarding formal obligations and the exercise of the right to deduction. The rulings confirm the application of specific forms (303, 309, 390) depending on the nature of the operations and reiterate the four-year period for the deduction of amounts incurred.
Analysis based on 55 of 60 rulings with a stated position. Updated 23 September 2026.