Questão jurídica principal
Whether losses from the business A. could be deducted as business losses from self-employment income.
Decisão extraída
No. The activity did not qualify as self-employment, so the claimed business-loss deduction was refused.
Fundamentação extraída
A self-employed activity requires at least medium-term income generation. The business had never generated revenue from 1999 to 2001, only expenses, and continued an earlier loss-making business; the taxpayers also failed to substantiate a sufficient link between their Spanish project work and A.