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V2908-14 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 is included in the IVPEE taxable base

A renewable energy company has requested clarification on whether the specific remuneration regime forms part of the taxable base for the tax on the value of electricity production (IVPEE). The Directorate-General for Taxes (DGT) has ruled that it does, encompassing both investment and operation 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 for the IVPEE consists of the total amount to be received for the production and incorporation of electric energy into the electricity system. In this calculation, the remunerations from all economic regimes derived from the Electricity Sector Law are considered. Therefore, the tax base includes the remuneration for the sale of energy at market price and the specific remuneration (investment remuneration and operation remuneration).

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