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V0417-26 26 February 2026 · SG de Tributos Locales Criterion in force
OTRO · impuesto sobre actividades económicas

Power of battery generators must be included in IAE calculation if energy transformation occurs

A photovoltaic energy producer asks whether it can use only the inverter's nominal power to calculate the IAE rate under heading 151.4. The DGT responds that if energy transformation occurs in battery systems, these must be considered part of the activity and their power must be included in the generator power calculation.

The question raised

It is asked, for the purposes of calculating the fee for heading 151.4 of the tariffs, whether only the nominal power of the photovoltaic plant inverter can be considered as the power in generators.

The DGT's ruling

For heading 151.4 of the IAE, the tax element is exclusively the power of the generators. Given that battery storage systems perform a transformation of electrical energy into chemical energy and its subsequent reconversion, they are not simple warehouses, but rather facilities directly related to the industrial activity. Therefore, if such transformation is carried out, the power of the battery generators must be included in the calculation of the generator power to determine the fee.

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