How the DGT's position has evolved
Current position
The reduction of positive net income is applied in the first period in which it is positive and in the following one, provided that the economic activity is maintained. For the commencement of activity, the taxpayer must determine their income through the direct estimation method and must not have previously commenced activity under regimes such as that for non-residents. In the context of rental, the 70% reduction requires that the lessee be a Public Administration or an entity under Law 49/2002 for social rental or vulnerability purposes, or that the housing be part of specific programs.
The DGT's position shows a specialization of the reduction scenarios. While the criterion regarding the commencement of activity and the temporality of the reduction remains constant, new modalities for the 70% reduction linked to protected and social housing have been incorporated. The doctrine has specified that the commencement of activity requires compliance with residency requirements and the direct estimation regime.
Turning points
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Introduces the possibility of applying the 70% reduction if the lessee is a non-profit entity under Law 49/2002 intended for social rental or vulnerability.
Analysis based on 50 of 50 rulings with a stated position. Updated 20 September 2026.