Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The determination of net income under direct estimation requires the application of the principle of correlation with income for the deductibility of expenses, as is the case with training. Expenses must be justified by an invoice and recorded in the accounting records. Likewise, certain income, such as the refund of RETA (Self-Employed Regime) contributions due to multi-activity or contributions paid by mutual insurance companies for temporary disability benefits, must be integrated or deducted according to their economic nature.
The sequence of rulings does not show a doctrinal evolution, but rather a dispersion of criteria regarding very diverse scenarios within direct estimation. Heterogeneous topics are addressed, ranging from the depreciation of livestock and the ownership of pharmacy licenses to limits on reductions for starting an activity and the deductibility of training. There is no change in position, but rather an application of general rules to specific cases.
Turning points
Specifies that the 20% reduction for starting an activity has an application limit on the first 100,000 euros of net income.
Analysis based on 28 of 29 rulings with a stated position. Updated 22 July 2026.