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V0334-26 19 February 2026 · SG de Tributos Locales Criterion in force
OTRO · iae

Battery energy storage facilities taxed under IAE heading 151.4

The consultant asks which IAE heading applies to storing and selling electricity purchased on the market. The DGT states that since energy is transformed chemically and back again, these installations constitute production rather than mere storage.

The question raised

It is desired to know the heading corresponding to the activity of storage and subsequent sale of electricity that has been previously acquired in the market, and whether, in this case, group 631 of the first section of the Economic Activities Tax Tariffs, relating to "Trade Intermediaries", would apply.

The DGT's ruling

Battery storage systems perform a transformation of electrical energy into chemical energy and its subsequent reconversion, therefore they are not warehouses or deposits. As a transformation process is carried out whose final product is electrical energy, they constitute an industrial production installation. Therefore, they must be taxed under heading 151.4 of the first section of the Tariffs. The payment of this fee entitles the holder to market the obtained product without the need for registration in commercial headings.

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