How the DGT's position has evolved
Current position
To access the objective estimation method in 2026, the limits for gross income and purchase volume for 2025 must be verified. The current limits are 250,000 euros for gross income and 250,000 euros for purchases of goods and services. In the year of commencement of activity, the taxpayer may apply the method regardless of their volumes, but must annualize the results of the first year to verify compliance in the following fiscal year.
The DGT's position remains stable regarding the limit control mechanism based on the previous year. The evolution shows a transition from the application of temporal imputation criteria (accrual or cash basis) towards the clarification of the continuity of limits following regulatory changes. No doctrinal shifts are observed, but rather clarifications regarding the calculation of income and the situation at the commencement of activity.
Turning points
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Specifies that the calculation of income and purchases must follow the taxpayer's temporal imputation criterion, whether accrual or cash basis.
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Establishes that at the commencement of activity, the method may be applied regardless of volumes, with the obligation to annualize results for the following year.
Analysis based on 10 of 10 rulings with a stated position. Updated 28 September 2026.