Doctrine by topic · DGT Observatory

Plurality of Activities: 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 12 rulings · 2014–2023

Current position

In the event of a plurality of activities, the rule of computing the entrepreneur as a non-salaried person is broken if a dedication of fewer than 1,800 hours/year is proven due to objective causes. The module is obtained by dividing the effective hours dedicated by 1,800. For management, organization, and planning tasks, a minimum of 0.25 persons/year is applied, unless a different dedication is proven. The taxpayer must prove said time through admitted means of evidence.

The DGT's position remains constant regarding the calculation of the module based on effective dedication in the case of a plurality of activities. The criterion has been maintained that the holder must be computed in full for each activity so that the spouse can be computed at 50%. Recent rulings reinforce the need to prove the hours through means of evidence.

Turning points

  1. V3211-14

    Establishes that for the 50% computation for the spouse, the holder must be computed in full for each activity, preventing the benefit if the holder is split among several activities.

Analysis based on 12 of 12 rulings with a stated position. Updated 27 September 2026.

Rulings on this topic

12

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