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V0164-15 19 January 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · investigación y desarrollo

A biodiesel pilot plant project may qualify as technological innovation if it involves a substantial improvement

The applicant asks whether their pilot plant project for biodiesel production via cavitation qualifies as R&D. The DGT determines it does not constitute R&D as it does not generate new knowledge, but it may qualify as technological innovation if it provides a novelty or a substantial improvement.

The question raised

Question posed: Whether the described activities can be classified as research and development for the purposes of the deduction provided for in Article 35 of the TRLIS.

The DGT's ruling

The project does not constitute research or development as it does not seek new knowledge or substantial technological improvements to the pre-existing state. However, it may be classified as technological innovation if the system design allows for the achievement of significant technological improvements and a substantial scientific or technological novelty. The pilot plant is considered an innovation activity provided it is used for testing and the acquisition of technical data, and not as a normal production unit or for experimental production.

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