Doctrine by topic · DGT Observatory

Exclusion of the Method: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 9 rulings · 2014–2025

Current position

The exclusion from the objective estimation method takes effect from the beginning of the year immediately following the one in which the cause for exclusion occurs. This exclusion requires the application of the simplified direct estimation modality for a minimum period of three years. To return to the objective estimation method, the taxpayer must meet the application requirements in the fiscal year immediately preceding the year of their return.

The DGT's position remains constant throughout the analyzed sequence. The rulings repeatedly confirm that exclusion generates an obligation to remain under direct estimation for three years and that returning to the objective method requires compliance with the limits in the previous year.

Analysis based on 9 of 9 rulings with a stated position. Updated 30 September 2026.

Rulings on this topic

9

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