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V1855-23 27 June 2023 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · amortización

Separate depreciation of structure and installation possible for photovoltaic plants with different useful lives

A company has enquired whether it can independently depreciate the support structure and the panels of a photovoltaic installation. The DGT has ruled that this is possible if the components are inherently separable, have different useful lives, and are significant.

The question raised

Whether, for depreciation purposes, it is possible to separately consider the components of tangible fixed assets intended for the structure that will support the installation, from the photovoltaic electricity producing installation itself.

The DGT's ruling

Each part of a tangible fixed asset that has a significant cost and a different useful life from the rest may be depreciated separately. In this case, the installation of panels may be considered a "renewable power plant" and the support structure could be classified as "other installations". The taxpayer must identify and separate the components using appropriate supporting documentation and certify the nature of each.

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