How the DGT's position has evolved
Current position
Net income is determined by the difference between income and expenses, the latter of which must comply with the principle of correlation with income and be duly justified with an invoice. In specific activities, such as pharmacy, income is imputed to the holder of the license or authorization. For objective estimation, compliance with the limits of Order HAC/1347/2024 and the absence of exclusion causes must be verified.
The sequence does not show a doctrinal evolution on a single concept, but rather presents dispersed criteria on various matters regarding net income. There is no trajectory of change, but rather an accumulation of specific criteria on objective estimation, valuation of fees, livestock depreciation, and deductibility of expenses.
Analysis based on 21 of 21 rulings with a stated position. Updated 26 July 2026.