How the DGT's position has evolved
Current position
Under the direct estimation method, expenses are deductible if it is proven that they were incurred in the course of the activity and are related to the generation of income. The rules of Corporate Income Tax (IS) are applied to determine the net yield. The link between the expense and the generation of income is a matter of fact that must be assessed by the management and inspection bodies.
The DGT's position remains constant in requiring proof of the correlation between the expense and the generation of income. Throughout the rulings, it is reiterated that the assessment of this link is a matter of fact for the Administration. No doctrinal changes are observed, but rather the application of linkage and justification criteria in different scenarios.
Analysis based on 35 of 35 rulings with a stated position. Updated 23 September 2026.