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A query was raised regarding whether the deferral of capacity payments depends on accounting imputation criteria. The DGT ruled that these payments may be integrated into the tax base annually throughout the useful life of the installation, regardless of when they are actually received.
Question raised: Confirm whether the spreading of capacity payments is conditioned by their accounting accrual criterion.
Annual remunerations for the investment incentive of capacity payments may be spread over time in the tax base of the tax in relation to the useful life of the installation, regardless of the fiscal year in which they are received. However, payments corresponding to periods prior to the entry into force of the tax (January 1, 2013) shall not be integrated into the tax base, remaining detached from the accounting criterion.
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