How the DGT's position has evolved
Current position
Expenses under the direct estimation method are deductible if they are linked to the economic activity and related to the generation of income. They must comply with correct temporal imputation, be recorded in the corresponding accounting or books, and be duly justified. The Tax Administration has the authority to assess said link.
The DGT's position remains constant regarding the requirement of general deductibility criteria: accounting registration, accrual, correlation with income, and documentary justification. Throughout the rulings, these principles have been applied to specific cases such as mobility, studies, or work-related relocation expenses, without altering the regulatory basis.
Analysis based on 37 of 39 rulings with a stated position. Updated 16 September 2026.