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V0500-20 27 February 2020 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · reserva para inversiones en canarias

Subscription of shares may trigger RIC if the issuing entity makes investments in the Canary Islands

An entity has enquired whether subscribing to shares in a company developing a wind energy prototype allows for the materialisation of the Canary Islands Investment Reserve (RIC). The DGT responds that this is possible if the issuer makes investments in tangible or intangible fixed assets, and specifies when the reserve is considered materialised.

The DGT's ruling

The subscription of shares is suitable for materializing the RIC if the issuing entity makes investments in tangible or intangible fixed assets (letters A or C of art. 27.4) and complies with the requirements of Law 19/1994. Materialization is understood to occur when the issuing entity puts the acquired assets into operation. Likewise, the sale of electricity produced in the Canary Islands is entitled to the bonus provided in article 26 of Law 19/1994.

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