How the DGT's position has evolved
Current position
Income from the provision of professional services is classified as income from economic activities due to the self-organized management of means. Funds received for disbursements, which belong to the client and are paid following a provision of funds, are not considered income from the activity. Net income must be determined using the direct estimation method.
The DGT's position remains stable regarding the classification of professional income as income from economic activities. The doctrine has clarified the nature of specific concepts, such as the distinction between clinical psychology services (exempt) and guidance services (at 10% or 21%), and the exclusion of funds for disbursements from the net income base.
Turning points
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Establishes the distinction between exempt clinical psychology services and guidance services or workshops taxed at 10% or 21%.
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Clarifies that funds for disbursements are not income from economic activities if they are paid following a provision of funds on behalf of the client.
Analysis based on 20 of 20 rulings with a stated position. Updated 25 September 2026.