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V3954-15 10 December 2015 · SG de Impuestos Especiales y de Tributos sobre el Comercio Exterior Criterion in force
OTRO · impuesto especial sobre la electricidad

No tax liability for Electricity Special Tax when discharging energy into the grid

A solar photovoltaic plant has requested clarification on whether it is liable for Electricity Special Tax when discharging its entire production into the grid without any self-consumption or supply to end consumers. The DGT has ruled that the taxable event for this tax does not occur, although the activity remains subject to the IVPEE.

The question raised

Liability for the Special Tax on Electricity.

The DGT's ruling

The supply of electricity is subject to tax when it is delivered to a person for their own consumption or when producers consume their own generated electricity. By feeding the entirety of the energy into the grid without supply to end consumers or self-consumption, the taxable event for the Special Tax on Electricity is not triggered. However, the production and incorporation of electricity into the electrical system is subject to the Tax on the Value of Electricity Production (IVPEE).

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