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V3314-15 27 October 2015 · SG de Tributos Locales Criterion in force
OTRO · impuesto sobre actividades económicas

Storing gases in customer tanks does not require IAE registration if it is not an independent activity

A query was raised regarding whether storing gases in cryogenic tanks located at a customer's premises triggers obligations under the Economic Activities Tax (IAE). The DGT ruled that delivery and storage do not constitute a separate taxable event; however, the installation of tanks owned by the company does constitute an independent activity.

The question raised

Consideration of so-called "cryogenic tanks at client premises" where gas is stored following its sale and delivery to the client's address, for the purposes of the Tax on Economic Activities.

The DGT's ruling

The delivery and storage of gases in client facilities does not generate an obligation to register under new tax headings, as it does not constitute a taxable event distinct from manufacturing or trade. However, if the company installs tanks of its own property, this does constitute an independent activity requiring registration under headings for assembly, machinery trade, or rental of movable property, as applicable. The sale of manufactured gases must take place at the same manufacturing premises to be included within the scope of the manufacturing tax headings.

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