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An energy sector company has requested clarification on whether revenue from value-added services should be included when calculating the municipal fee for the use of surface, subsoil, or airspace, or if only electricity supply revenue applies. The Directorate-General for Tax (DGT) has ruled that only the gross billing revenue derived from services provided through the use of said public domain may be imputed.
This ruling limits the scope of local tax bases for public domain usage fees, ensuring that only revenue directly linked to the use of the public space is taxed, thereby preventing the inclusion of ancillary service revenues.
The tax team reviews your specific situation.
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