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 constituted by the total amount received for the production and incorporation of electric energy into the electrical system. In bilateral contracts, the remuneration is fixed according to the price of the firm contracted operations. Financial agreements for the hedging of price fluctuations are not included in the tax base.
The DGT's position remains constant in defining the tax base as the total amount for production and incorporation into the system. The evolution shows greater technical precision by integrating concepts from the specific remuneration regime and, finally, by excluding financial hedging agreements in bilateral markets.
Turning points
Clarifies that the tax base includes both the remuneration for the sale of energy and the specific remuneration (investment and operation).
Establishes that the hedging of price fluctuations through financial agreements does not form part of the tax base.
Analysis based on 27 of 27 rulings with a stated position. Updated 24 September 2026.