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V2907-14 30 October 2014 · SG de Impuestos Especiales y de Tributos sobre el Comercio Exterior Criterion in force
OTRO · ivpee

Specific remuneration for investment and operation forms part of the IVPEE taxable base

A renewable energy company has requested clarification on whether payments under the specific remuneration regime are included in the tax base. The Directorate-General for Taxes (DGT) has ruled that they are, encompassing both investment remuneration and operational remuneration.

The question raised

Confirm whether the remuneration received under the specific remuneration regime forms part of the tax base.

The DGT's ruling

The tax base of the IVPEE consists of the total amount corresponding to be received for the production and incorporation into the electricity system of electric energy. Therefore, the remuneration for the sale of energy valued at the production market price and the specific remuneration received, both for the concept of investment remuneration and for the concept of operational remuneration, form part of said tax base.

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