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V0550-20 6 March 2020 · SG de Tributos Locales Criterion in force
OTRO · impuesto sobre actividades económicas

Single minimum tax levy applies if liquid tanks are located within a single premises

The query examines whether an installation comprising several interconnected tanks should be taxed individually or as a single unit. The Directorate General for Taxes (DGT) rules that if the tanks are situated within a single enclosure without separating streets or walls, they constitute a single premises for the purposes of the Economic Activities Tax (IAE).

The question raised

It is desired to know how a private facility located on a single surface, delimited from the exterior by fences and walls, without public roads passing through it, consisting of several liquid storage tanks interconnected to a common piping circuit, should be taxed regarding the tax element that constitutes the fee for heading 754.5.

The DGT's ruling

Tanks, spheres, or cisterns located within a single enclosure constitute a single premises for IAE purposes, provided they are not separated by streets, roads, or continuous walls without passages. Access roads within the perimeter of the facility are not considered streets or roads, but rather an integral part of the premises. Therefore, a single municipal fee shall be levied for the warehouse or depot, regardless of the number of tanks composing it.

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