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V0096-26 20 January 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · reserva para inversiones en canarias

Acquisition of industrial vessels could trigger Canarias Investment Reserve if letter C conditions met

A Canary society asks whether purchasing industrial vessels owned by its partners could count as triggering the Canarias Investment Reserve (RIC). The DGT states it would not qualify as an initial investment but notes it could qualify under letter C of the regulations.

The question raised

Whether it is possible to realize said investment in the RIC in application of the provisions of Article 27.4 of Law 19/1994, of July 6, amending the Economic and Tax Regime of the Canary Islands.

The DGT's ruling

The acquisition of the warehouses does not constitute an initial investment pursuant to letter A of Article 27.4 of Law 19/1994. However, the investment could be considered eligible to realize the RIC under letter C, provided it is carried out within three years from the accrual. Regarding the land, it must be allocated to the development of industrial activities included in divisions 1 to 4 of the first section of the IAE tariffs.

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