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V0337-26 19 February 2026 · SG de Tributos Locales Criterion in force
OTRO · iae

Battery energy storage systems counted as electricity production under heading 151.4

A company asked whether its battery energy storage systems could be considered warehouses for IAE purposes. The DGT replied that since these systems involve converting electrical energy into chemical energy and vice versa, they constitute industrial activities in the production of electricity.

The question raised

It is desired to know:

The DGT's ruling

Battery storage systems are not simple storage facilities, as they transform electrical energy into chemical energy and subsequently reconvert it into electrical energy. Therefore, they constitute industrial facilities for the production of electrical energy classifiable under heading 151.4. If the activity is hybrid or autonomous, the taxpayer must pay tax on the power of the generators under said heading, which entitles them to the commercialization of the product without an additional registration in commercial headings.

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