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V0335-26 19 February 2026 · SG de Tributos Locales Criterion in force
OTRO · iae

Battery energy storage installations taxed under IAE heading 151.4

The consultant asks which IAE heading applies to storing and selling electricity purchased on the market. The DGT replies that since energy is transformed chemically and back again, it is not mere storage but a production activity.

The question raised

It is desired to determine the heading corresponding to the activity of storing and subsequently selling electricity that has been previously acquired in the market, and whether, in this case, group 631 of the first section of the 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 there is a transformation process where the final product is electrical energy, they constitute an industrial production facility. Consequently, 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 rubrics.

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