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V2317-16 25 May 2016 · SG de Impuestos Especiales y de Tributos sobre el Comercio Exterior Criterion in force
OTRO · ivpee

Specific remuneration for investment and operation is included in the IVPEE taxable base

A query was raised regarding whether remuneration under the specific remuneration regime forms part of the taxable base for the Electricity Production Value Tax (IVPEE). The Directorate-General for Taxes (DGT) ruled that it does, encompassing both investment remuneration and operation remuneration.

The question raised

Confirm whether the remuneration received under the specific remuneration regime forms part of the tax base of the Tax on the Value of Electric Energy Production.

The DGT's ruling

The tax base for the IVPEE consists of the total amount corresponding to be received for the production and incorporation of electric energy into the electricity system. The concepts comprising the specific remuneration regime (investment remuneration and operation remuneration) form part of the tax base. This is because said remunerations correspond to payments linked to the production and incorporation of electric energy into the system.

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