Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The tax base for the IVPEE (Special Tax on the Production and Incorporation of Electricity into the Electrical System) is the total amount received for the production and incorporation into the electrical system of energy measured in power plant busbars. For energy traded in bilateral contracting markets, the remuneration is set according to the price of the firm contracted operations. In contracts between independent entities, the value shall be the agreed price, regardless of its calculation method.
The DGT's position remains constant in the definition of the taxable event and the tax base. The rulings have reiterated that the tax levies energy measured in power plant busbars that is incorporated into the system. No changes are observed in the substantive criterion, only clarifications regarding the self-assessment and the valuation of bilateral contracts.
Analysis based on 14 of 14 rulings with a stated position. Updated 26 September 2026.