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 Electricity Production and Incorporation into the Electricity System) includes the total amount received for the production and incorporation of electric energy into the electricity system, integrating both the remuneration for the sale of energy and the specific remuneration (investment and operation). The self-consumption of the energy generated constitutes a taxable event, although there is an exemption for holders under the specific remuneration regime who possess the electricity identification code (CIE). The CNMC (National Commission on Markets and Competition) settlements for price differences from previous financial years do not form part of the tax base for the current financial year.
The DGT's position remains constant regarding the integration of specific remunerations into the IVPEE tax base. The requirements for the self-consumption exemption have been specified, strictly linking it to registration in the registry with the CIE code. Finally, it has been delimited that income from CNMC settlements from previous financial years does not count towards the tax base of the current year.
Turning points
Establishes the exemption for energy consumed by holders under the specific remuneration regime, conditioned upon registration in the registry with the CIE code.
Determines that CNMC settlements for price differences from previous financial years do not form part of the tax base for the current financial year.
Analysis based on 11 of 11 rulings with a stated position. Updated 27 September 2026.