How the DGT's position has evolved
Current position
Natural persons taxed under the objective estimation method for Personal Income Tax (IRPF) and under the simplified special regime for Value Added Tax (IVA) are excluded from the obligation to file the annual return of transactions with third parties (Form 390). This exclusion does not affect operations for which an invoice is issued. Furthermore, they must include the acquisition of goods and services in their registration book.
The DGT's position on the simplified special regime remains stable regarding the exclusion of activities such as VTC transport or vehicle rental with a driver. Recent rulings focus on operational aspects such as the annual return of transactions with third parties and the management of investment quotas.
Turning points
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Clarifies the exclusion from the obligation to file the annual return of transactions with third parties for those taxed under the objective estimation method and the simplified regime.
Analysis based on 41 of 46 rulings with a stated position. Updated 23 September 2026.