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V1912-23 4 July 2023 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · reserva de inversiones en canarias

Investment in a new wind turbine and civil works may qualify for the Canary Islands Investment Reserve

A company in the Canary Islands has requested a ruling on whether the purchase of a new wind turbine and the civil works required for its commissioning qualify for the Canary Islands Investment Reserve (RIC). The Directorate-General for Tax (DGT) indicates that the investment in the wind turbine may be eligible as it contributes to environmental protection, and that the associated civil works are subsumed under this concept.

The question raised

Whether the investment in the new wind turbine and the civil works are eligible for the realization of the Canary Islands Investment Reserve.

The DGT's ruling

The investment in the new wind turbine may be considered eligible for the RIC under letter C of Article 27.4 of Law 19/1994, as it contributes to the improvement and protection of the environment in the Canary Islands territory. The civil works necessary for its commissioning are considered part of the acquisition cost of the tangible fixed assets and are subsumed within the same category. If the new generator replaces others that have already realized the RIC, only the portion exceeding the net book value of the replaced elements may be considered a realization.

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