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Renunciation: evolution of DGT doctrine

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 15 rulings · 2014–2026

Current position

The revocation of the renunciation of the objective estimation method must be carried out obligatorily through a census declaration in the month of December of the year prior to the one in which it is to take effect. Tacit revocation through the submission of installment payments is not permitted. Express renunciations remain in force unless they are formally revoked.

The DGT's position has consolidated around the formality required for the revocation of the renunciation of the objective estimation method. Since the 2020 rulings, the Administration has systematically rejected the possibility of carrying out tacit revocations, requiring the use of the census declaration within the established deadlines.

Turning points

  1. V3072-20

    Establishes that the determination of yields under the normal modality implies a renunciation of the simplified method, with a minimum effect of three years.

  2. V0994-24

    Clarifies that revocation cannot be carried out tacitly through the submission of installment payments.

Analysis based on 14 of 15 rulings with a stated position. Updated 26 September 2026.

Rulings on this topic

15
V1650-15 27 May 2015

Written waiver possible for previously requested higher withholding rate

SG de Impuestos sobre la Renta de las Personas Físicas
retencionesrendimientos del trabajotipo de retención superiorpagadorrenuncia RIRPF — RD 439/2007, Reglamento del IRPF art. 88.5LGT — Ley 58/2003 General Tributaria art. 89.1
Affects CompanyExpat · Non-residentIndividual

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