How the DGT's position has evolved
Current position
Expenses are deductible for Personal Income Tax (IRPF) and Corporate Tax (IS) if they are proven to be incurred in the course of the activity and comply with the principle of correlation with income. They must be correctly imputed on an accrual basis, recorded in the accounting records, and justified by an invoice or equivalent document. The link to the activity must be proven through means admitted by law.
The DGT's position remains constant regarding the general requirements for deductibility: correlation with income, accounting records, and documentary justification. Throughout various rulings, the administration has applied these principles to specific cases such as rent, medical expenses, or remuneration, without altering the doctrinal basis established in 2014.
Analysis based on 63 of 63 rulings with a stated position. Updated 18 September 2026.