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Incompatibility of Methods: 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 10 rulings · 2014–2024

Current position

The application of the direct estimation method to an economic activity obliges the taxpayer to apply said method to all their other activities due to incompatibility with the objective estimation method. This obligation to unify methods does not take effect in the tax year in which the activity requiring direct estimation begins. The transition towards direct estimation for all activities will become effective as of the following tax year.

The DGT's position remains stable regarding the incompatibility between estimation methods. The evolution focuses on precision regarding the timing of the application of the incompatibility, clarifying that the change of method does not affect previous activities during the year the new activity begins, as observed in rulings V2159-20 and V2354-21.

Turning points

  1. V2159-20

    Clarifies that the incompatibility does not affect activities already carried out in the year a new activity not included in the objective estimation begins.

Analysis based on 10 of 10 rulings with a stated position. Updated 28 September 2026.

Rulings on this topic

10

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