Taxes and
incentives for
renewable
energy
KPMG INTERNATIONAL
September 2013
kpmg.com/energytax
This report describes the 2013 taxes and
incentives provided by 28 countries around the
world to promote renewable energy from wind,
solar, biomass, geothermal and hydropower.
These policies also support other areas such
as increased energy efficiency, smart-grid
management, biofuels, carbon capture systems
and storage technologies. Content includes an
introduction about global trends in renewables,
a summary of investments in renewable
energy, and a brief outline of renewable energy
promotion policies in all 28 countries.
André Boekhoudt
Head of Global Energy
and Natural Resources
Tax Practice
Lars Behrendt
Tax Partner, KPMG in
Germany
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Contents
Introduction
1
2013 Industry trends
2
Global investment in renewable energy production
3
Renewable energy promotion policies by country
5
Argentina
7
Australia
8
Austria
10
Brazil
11
Canada
13
China
16
Denmark
18
France
20
Germany
22
India
24
Ireland
26
Italy
28
Japan
31
Mexico
32
The Netherlands
34
New Zealand
36
Norway
37
Peru
39
Poland
40
Romania
41
South Africa
43
South Korea
45
Spain
46
Sweden
49
Turkey
50
United Kingdom
51
United States
53
Uruguay
55
Top five countries 2012
57
Appendix A: REN21 2012 Renewables Global Status Report
58
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
1 | Taxes and incentives for renewable energy
Introduction
Renewable energy continues to be
one of the world’s strongest growth
industries. Consider these facts:
• Approximately20percentofglobal
electricity generation now comes from
renewable energy sources.
1
• Renewablesaccountedforover
half of total net additions to electric
generating capacity worldwide
in 2012.
2
• Almost70percentofnewelectric
generating capacity in the European
Union (EU) for 2012 came from
renewables.
3
• Solarphotovoltaic(PV)electricity
generation soared from 10 gigawatts
(GW) in 2007 to over 100 GW in 2012.
4
This rapid increase in renewables is
driven by a number of factors, including
falling technology costs, rising fossil-fuel
prices and carbon pricing. However,
the main support for growth is through
government incentives, which totaled
United States dollar (USD)88 billion
globally in 2011.
5
This report describes current incentives
provided by 28 countries around the
world to promote renewable energy
from wind, solar, biomass, geothermal
and hydropower. These incentives
also support related areas such as
increased energy efficiency, smart-grid
management, biofuels, carbon capture
systems and storage technologies.
Governments now offer a wide
variety of tax incentives and related
programs to support renewable energy
investment, including:
• credits
• grants
• taxholidays
• accelerateddepreciation
• non-taxincentives.
Governments also play a role in
discouraging carbon emissions by
enforcing taxes and penalties such as:
• carbontaxandpricing
• capandtradeschemes
• indirecttaxes,suchasenergy
taxes, excise taxes or value
addedtaxes(VATs).
The 12 most common policies can be
divided into three categories:
• Regulatorypolicies:
– renewable energy targets
– feed-in tariff/premium payment
– electric utility quota obligation/
renewable portfolio standard (RPS)
– net metering
– biofuels obligation/mandate
– heat obligation/mandate
– tradable renewable energy
credit (REC).
• Fiscalincentives:
– capital subsidy, grant and rebate
– investment and production tax
credits
– reductions in sales taxes, energy
taxes, CO
2
taxes,VATandother
taxes
– energy production payment.
• Publicnancing:
– public investment, loans and
grants
– public competitive bidding/
tendering.
These policies and incentives have
proven their effectiveness over the past
decade. By the end of 2012, at least
138 countries had renewable energy
targets, an increase of 66 percent from
2007.
6
Some 120 countries have various
types of policy targets for long-term
shares of renewable energy. The EU is
maintaining its target of 20 percent by
2020.
7
Several European countries in
particular have even stronger national
long-term targets that will place them in
the high renewables range by 2030 or
2050, including Denmark (100 percent)
and Germany (60 percent).
8
Outside of Europe, at least 20 other
countries have targets in the 2020–
2030 time frame ranging from 10 to
50 percent. These include Algeria,
China, Indonesia, Jamaica, Jordan,
Madagascar, Mali, Mauritius, Samoa,
Senegal, South Africa, Thailand, Turkey,
Ukraine,andVietnam.
9
(For additional information about these
policies, see appendix A/page 57).
1
World Energy Outlook 2012 – Executive Summary
2
Ibid.
3
REN 21 Renewables 2013 Global Status Report
4
Ibid.
5
Op. cit., World Energy Outlook 2012
6
Op. cit., REN 21 Renewables 2013 Global Status Report
7
REN 21 Renewables 2013 Global Futures Report
8
Ibid.
9
Ibid.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Taxes and incentives for renewable energy | 2
2013 Industry trends
The global energy system based
on hydrocarbons is undergoing a
foundational shift. No one disputes the
need for increased energy supplies.
Global demand for electricity is
expected to rise by more than
80 percent from 2010 to 2040, driven
by an increase in total population and
gross domestic product (GDP) output.
To address world energy demand, the
energy industry has seen a recent
resurgence in oil and gas production,
led by the “shale gale” of natural gas
made available with hydraulic fracturing
(fracking) and horizontal drilling in
the US In addition, global fossil fuel
subsidies rose almost 30 percent to
USD523 billion in 2011, primarily for oil
development in the Middle East and
North Africa.
10
Nevertheless, the feasibility of a
carbon-based energy system is being
questioned. Economic development
across Europe is hampered by
continued high oil prices, and signs of
an unsustainable energy system persist,
with CO
2
emissions at a record high.
Accordingly, economies around the
world are increasing their dependence
on sustainable energy sources to
help reduce greenhouse gas (GHG)
emissions and pollutants. Renewables
have also been recognized as a way to
stimulate economies, enhance energy
security and diversify energy supply.
In terms of renewables policy, the EU
continues to lead the world in its support
for less carbon-intensive electricity
generation, with 65 percent of electricity
now being generated from nuclear and
renewable fuels. Europe increased its
wind energy capacity by 12.3 percent
in 2012,
11
and 20 percent of Europe’s
power is targeted to come from wind
generation by 2040. A European
Commission report indicated that
renewable energy could meet 55 to
75 percent of final energy consumption
by 2050, compared to less than
10 percent in 2010.
12
The United States is expected to see a
significant growth in domestic natural
gas production, which might impact
policies that support renewables.
Continued low gas prices, for example,
would likely reduce the value of
purchase price agreements available to
generators, including wind developers.
However, the federal Production Tax
Credit for wind was extended for a
further year by Congress at the start of
2013. The Clean Energy Standard Act of
2012 is currently under consideration
by the US Congress, and this law would
set the first nationwide targets for clean
electricity, defined as energy produced
from renewables, nuclear power and
gas-fired generation. The Renewable
Fuel Standard, adopted in 2005 and
extended in 2007, mandates 36 billion
gallons of biofuels to be blended into
transportation fuel by 2022.
In China, electric energy demand is
expected to more than double by
2040.
13
Despite the continued use of
large amounts of coal and gas, China is
also adopting the European and the US
approach to shift electricity generation
away from coal. China’s renewables
policy is based on the 2005 Renewable
Energy Law. In 2009, China set a target
to increase the share of non-fossil
energy (nuclear and renewables) in the
power sector to 15 percent by 2020.
The 12th Five- Year Plan (2011-2015) calls
for 70 GW of additional wind capacity,
120 GW of additional hydropower and 5
GW of additional solar capacity by 2015.
Targets have also been set for the first
time for geothermal and marine power.
Japan’s renewables energy policy
was reviewed and extended through
legislation passed in 2009 and a revised
Basic Energy Plan in 2010. After the
events at Fukushima, the government
announced the Innovative Strategy
for Energy and the Environment in
September 2012, which includes the
goal of reducing the role of nuclear
power. This will be supported in part by
increasing the deployment of renewable
energy. By 2030, the strategy calls for
power generation from renewables to
triple compared to 2010, reaching about
30 percent of total generation. In July
2012, Japan launched a new feed-in
tariffs system for wind and solar power
and other renewables, providing a
generous amount of incentives.
Overall, the global adoption rate of
renewables policies has slowed
considerably, especially as compared
to the early-to-mid 2000s. Revisions
to existing policies are becoming
increasingly more common, as well
as new types of policies that combine
energy-efficiency measures with the
implementation of renewable energy
technologies.
14
Looking ahead, recent analysis has
suggested that the following global
milestones will be reached by 2035:
15
• Demandforelectricitywillgrowby
over 70 percent.
• Overallenergydemandwillriseby
over 30 percent.
• Generationfromrenewableswill
increase to almost three times its
2010 level.
• Theshareofrenewablesinthe
generation mix will increase to
31 percent.
Greater energy efficiency in building,
heating, transportation and
manufacturing will help offset the rise in
energy demand. However, renewables
will play a vital role in addressing
this demand in an environmentally
supportive and sustainable manner.
10
Op. cit., World Energy Outlook 2012
11
EurObserv’ER, Wind Power Barometer
12
Rethinking 2050, European Renewable Energy Council, 2010
13
Op. cit., World Energy Outlook 2012
14
Op. cit., REN 21 Renewables 2013 Global Status Report
15
OECD, International Energy Association (IEA), World Energy Outlook 2012, REN
21 Renewables 2013 Global Futures Report
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
3 | Taxes and incentives for renewable energy
Global investment in
renewable energy production
In 2012, global investments in
renewables reached USD244 billion.
This figure represents a decrease of
12 percent.
16
Investment levels in 2013
have followed this trend. As of Q1
2013, global investment in renewables
reached only USD40 billion, the lowest
in any quarter since Q1 2009 and a
decrease of 36 percent from the final
quarter of last year and 24 percent
below the first quarter of 2012.
17
This decline can be explained by several
factors, starting with uncertainty
about renewables policy in developed
economies. Investments declined
34 percent in the US because of policy
uncertainty, and former champions
for renewables in Europe such as Italy
and Spain saw significant contractions
based on policy changes and cuts in tariff
supports. The decline in investments
was also driven by overcapacity
in the manufacturing supply chain
in North America and Europe.
In addition, dramatically lower prices
for renewable energy have discouraged
investors. Solar prices dropped 30 to
40 percent between 2011 and 2012,
driven mainly by low-cost manufacturing
in China.
18
Wind turbine prices dropped
by 20 to 25 percent in western markets
and by 40 percent in China.
19
Another key trend in renewables
investment for 2012 was the continued
north to south shift toward emerging
markets. In 2007, developed economies
invested 2.5 times more in renewables
than the south. Now the gap has shrunk
to 18 percent, and emerging markets
are on track to surpass the north in
the next few years. Total renewables
investment in developing economies
rose 19 percent in 2012 to USD112
billion, while investment in developed
countries dropped 29 percent to
USD132 billion.
20
China, South Africa,
Morocco, Mexico, Chile and Kenya all
showed sharp increases in investment.
21
Significantly, incentives have been
maintained or increased in many Asian
countries even as they were being
reduced in many developed countries.
According to the REN21 Renewables
2013 Global Status Report, the top five
countries for new capacity investments
in renewable energy in 2012 were China,
the United States, Germany, Japan and
Italy. In KPMG’s Green Tax Index focusing
on fiscal incentives, China ranked
sixth, the United States ranked first,
Germany fifteenth and Japan second.
Italy was not included in this report.
(For additional information,
see appendix A/page 57)
16
Global Trends in Renewable Energy Investments 2013,
Bloomberg New Energy Finance
17
Ibid.
18
Ibid.
19
Bloomberg New Energy Finance, IHS Research
20
Ibid.
21
Op. cit., Global Trends in Renewable Energy Investment 2013
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Taxes and incentives for renewable energy | 4
China:
China was the dominant country in 2012
for investments in renewable energy,
with commitments rising 22 percent to
USD67 billion, representing 27 percent
of global renewables investment.
22
This
surge was due mainly to a spike in solar
investment.
23
Since 2005, China has
increased its renewables investment by
over 300 percent.
The government’s support for
renewables in China includes reduced
corporate income taxes, significant
reductions in value added taxes, feed-
in tariffs, R&D incentives, subsidies
for energy conservation technologies
improvement, and other tax incentives.
In a related note, Chinese companies
have provided nearly USD40 billion
to solar and wind industries in other
countries over the past decade.
24
Most
investments have gone to the US,
followed by Germany, Italy and Australia.
China’s wind industry supports the
domestic market, but the solar industry
relies on the international market for
95 percent of its sales.
25
More on page 16
United States:
The US ranked second in 2012 for
renewables investments, with a total
of USD36 billion. This represents a
drop of 34 percent over the previous
year. Most investment dollars went
to asset finance, while the remaining
portion went to public markets, venture
capital/private equity, corporate and
government R&D and small distributed
capacity.
Suggested strategies to increase the
US investments in renewables involve
a greater alignment of state, federal
and private efforts. At the state-level,
renewable energy portfolio standards
(RPS) and policies like electricity market
design have been proven successful.
These can complement federal
production and investment tax credits.
From the private sector, policies such as
Master Limited Partnerships (MLPs) and
Real Estate Investment Trusts (REITs)
can help provide lower-cost capital.
More on page 53
Germany:
Although Germany led the world in
renewable power per capita for 2012,
26
investments fell 35 percent from
previous year to USD20 billion.
27
Feed-
in tariffs are available in Germany for
wind, solar, geothermal, methane gas
and hydro generation. The government-
owned bank KfW also provides various
subsidies and support programs for
renewables. However, a major shift
away from nuclear plants and the
upcoming elections in September
2013 have introduced a high level of
uncertainty for investors. Feed-in tariffs
are expected to be cut, and other
reductions in incentives are expected.
More on page 22
Japan:
After the Fukushima earthquake, Japan
introduced several significant incentives
to support the move from nuclear to
renewable energy sources. These
include a special depreciation of
30 percent or 100 percent for the
purchase and installation of qualified
renewable energy equipment. In
addition, the government introduced an
incentive for fixed assets tax on certain
renewable energy generation facilities.
Not surprisingly, 2012 investments
in renewables increased 73 percent
over 2011 to USD16 billion.
28
Most
investments were for small-scale solar
PVfacilitiesthatpromiseafasterreturn
on investment. Goldman Sachs Group
Inc. (GS) has announced plans to invest
as much as USD487 million in renewable
energy projects in Japan in the next five
years.
29
Japanese banks and financial
institutions such as Softbank Corp. and
Orix Corp. have also shown considerable
interest in renewables investment.
30
More on page 31
Italy:
The renewable energy sector in Italy is
considered by some to have the highest
potential in the EU.
31
The country has
a well-developed system of incentives
(mainly feed-in tariffs) for renewable
energy generated from solar, wind and
biomass. In particular, the government’s
Renewable Energy Decree, which
entered into force on 29 March 2011,
revises the system of incentives for the
production of electricity from renewable
sources and simplifies the authorization
process for building new plants.
Nevertheless, the prolonged European
nancialcrisis,lowerPVcostsandother
factors have made their impact on the
sector. In 2011, Italy attracted USD29
billion in renewable energy investment,
but asset financing of renewable energy
in 2012 dropped 31 percent as compared
to 2010.
32
Investment from asset finance,
public markets and private equity was
down 26 percent.
33
More on page 28
22
Ibid.
23
Ibid.
24
China invests billions in international renewable energy projects,
WRI Insights, wri.org
25
Ibid.
26
not including hydro
27
Op. cit., Global Trends in Renewable Energy Investment 2013
28
Renewable energy investments shift to developing nations, Bloomberg,
12 June 2013
29
Goldman Sachs Eyes Japan Renewable Energy Investments, Bloomberg,
20 May 2013
30
Ibid.
31
Italy’s Renewable Energy Sector Continues to Attract Investors, According
to Mergermarket, Mergermarket, 9 May 2013
32
Can Italy Keep Its Renewables Investors?, RenewableEnergyWorld.com,
23 July 2013
33
Ibid.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
5 | Taxes and incentives for renewable energy
Renewableenergypromotion
policies by country
The following chart is a summary of the support schemes available in the 28 countries that are highlighted in this publication.
Additional details regarding the investment and operating support schemes for each country can be found in the following pages.
Australia
Renewable energy
targets
Feed-in tariff/
premium payment
Electric utility
quota obligation/
RPS
Net metering
Biofuels obligation/
mandate
Heat obligation/
mandate
Tradable REC
Capital subsidy,
grant, or rebate
Investment or
production tax
credits
Reductions in
sales, energy, CO
2
,
VAT or other taxes
Energy production
payment
Public investment,
loans, or grants
Public competitive
bidding/tendering
Austria
Canada
Denmark
France
Germany
Italy
Netherlands
New Zealand
Norway
Poland
South Korea
Spain
34
Sweden
United Kingdom
United States
REGULATORY POLICIES AND TARGETS FISCAL INCENTIVES
PUBLIC
FINANCING
Some states/
provinces within
these countries have
state/provincial-level
policies but there is no
national-level policy.
Argentina
China
Romania
Turkey
Mexico
Peru
South Africa
Brazil
Source: This section is intended only to be indicative of the overall landscape of policy activity and is not a definitive reference. Policies listed are generally those tha
have been enacted by legislative bodies. Some of the policies listed may not yet be implemented, or are awaiting detailed implementing regulations. It is obviously
difficult to capture every policy, so some policies may be unintentionally omitted or incorrectly listed. Some policies may also be discontinued or very recently
enacted. This report does not cover policies and activities related to technology transfer, capacity building, carbon finance, and Clean Development Mechanism
projects, nor does it highlight broader framework and strategic policies – all of which are still important to renewable energy progress. For the most part, this report
also does not cover policies that are still under discussion or formulation, except to highlight overall trends. Information on policies comes from a wide variety of
sources, including the International Energy Agency (IEA) Renewable Energy Policies and Measures Database, the U.S. DSIRE database, RenewableEnergy-
World.com, press reports, submissions from country-specific contributors to this report, and a wide range of unpublished data. Much of the information presented
here and further details on specific countries appear on the “Renewables Interactive Map” at www.ren21.net. It is unrealistic to be able to provide detailed
references to all sources here. REN 21 Renewables 2013 Global Status Report.
t
34
In Spain, the feed-in tariff (FIT) and net metering programmes have been temporarily suspended by Royal Decree for new renewable energy projects; this
does not affect projects that have already secured FIT funding. The Value Added Tax (VAT) reduction is for the period 2010–12 as part of a stimulus package.
India
Ireland
Uruguay
Japan
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Taxes and incentives for renewable energy | 6
Market issues
To help clients address key challenges
in today’s rapidly evolving renewable
energy sector, KPMG member firms
provide services backed by a global
network of resources, information and
experience. The KPMG Energy & Natural
Resources practice has specialists in
the field of renewable energy, based
in key business locations around the
world, acting as a single network. In
each location, KPMG professionals
can offer practical, in-depth, renewable
energy experience. They can also draw
on the KPMG global network of Energy
& Natural Resources practitioners to
provide clients with immediate access
to the latest industry knowledge, skills,
resources and technical developments.
With regular calls and effective
communications tools, we can share
observations and insights, debate new
emerging issues and discuss issues
that are critical to clients’ management
agendas. This global network also
produces publications and commentary
on key issues affecting the sector,
business trends, changes in regulations
and the commercial, risk and financial
challenges of doing business.
KPMG’s ENR Tax Services &
Solutions – engaging the green
agenda
KPMG firms can help you to review
your regulatory and sustainability
business strategies and your energy
and emissions trading objectives.
We can provide tax characteristics
of carbon credits, resolve Clean
Development Mechanism issues, and
define implications of Certified Emission
Reduction forward contracts from both
trading and transfer pricing standpoints.
We can also help you navigate the
wide array of available global and
local government and municipal grant
programs or tax incentives related to
the production and sale and purchase
of alternative energy and green
products. These include feed-in tariffs,
tax holidays, accelerated depreciation,
carbon tax/pricing, trading schemes,
energytaxes,excisetaxesorVAT
in relation to wind, solar, biomass,
biofuels, geothermal and hydropower
sources, as well as increased energy
efficiencies, smart-grid technologies,
and carbon capture and storage
technologies.
Due to the impact of these incentives
and taxes on your investment decisions,
KPMG firms can factor them into
tailored due diligence and tax modeling
services. These services apply not only
to production or sale/purchase of green
goods but also to green investments
and financing arrangements.
KPMG’s Global ENR Tax network
includes professionals who specialize in
these tax practice areas:
• FinancialServicesTax
• GlobalIndirectTax
• GlobalTransferPricingServices
• InternationalCorporateTax
• Mergers&Acquisitions.
Investing in the sector
KPMG member firms invest significant
time and resources in deepening our
understanding and knowledge of the
sector. This enables us to provide clients
with strategic and insightful services
that are tailored to their specific needs
and based on an understanding of their
challenges.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
7 | Taxes and incentives for renewable energy
Argentina
Support schemes
Investments and other subsidies
Support is available for renewable
energy sources including biofuels, solar,
wind, hydro and geothermal, among
others.
At the local tax level:
• Anticipatedvalueaddedtax(VAT)
refunds for the new depreciable
property (except for automobiles)
included in the project.
• Acceleratedincometaxdepreciation.
(filing two claims for the same project
are not allowed).
The property used for the project will
not be part of the minimum presumed
income tax taxable base. In addition,
biofuel producers will not be subject to
the hydric infrastructure tax, the tax on
liquid fuels and the gas oil tax for the
amount of fuel that is marketed in the
national territory.
At the provincial level:
• realestatetaxexemption
• stamptaxexemption
• turnovertaxexemption/deferral
• taxstability.
The type of benefit depends on the
geographic area in which the renewable
energy plant operates, so the plant’s
specific location must be supplied for a
proper tax classification.
Operating subsidies
Subsidiesatthenationallevel:
• Wind:0.015Argentinepeso
(ARS)/ kWh
• Solar:0.9ARS/kWh
• Hydroforlessthan30MWinstalled
capacity: 0.015 ARS/kWh
• Other:0.015ARS/kWh.Several
provinces have different incentive
feed-in tariffs according to the kind of
energy they want to promote.
Quota obligation
The aim is to reach a contribution of
sources of renewable energy equal
to eight percent of the total national
consumption of electric energy within
a term of 10 years, starting in 2006, the
effective date of the regime.
Quota obligations also include the
use of fossil fuel mixed with at least
five percent of biofuels, including
biodiesel and bioethanol.
Additional information
The following authorizations are
required for the construction of
renewable energy plants:
• authorizationtousetheland
• environmentalimpactstudy
• approvalbytheEnergySecretariat
• biddingoffersubmittedthrough
the Program of Electric Generation
through Renewable Energies
(Programa Generación Renovable or
GENREN).
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Taxes and incentives for renewable energy | 8
Australia
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
Investments and other subsidies
Australia’s clean energy sector is
currently experiencing significant
change in the wake of the Australian
government’s introduction of the
Securing a Clean Energy Future Climate
Change Plan (the Plan). The Plan has
initiatives in four key areas – carbon
pricing, renewable energy, energy
efficiency and land management. The
government has released numerous
federal funding initiatives within the
Plan, many of which are applicable
to renewable energy. There are also
a number of policies, programs and
incentives outside of the Plan, with
key initiatives specifically related to
renewable energy that are described
below.
Carbon Price Mechanism (CPM)
Central to the Plan is the introduction
of a CPM. Revenue generated from
the CPM will be invested to alleviate
the impact of price increases, support
more jobs and encourage innovations
addressing climate change. Enhanced
support for renewable energy is
expected to drive innovation and
investment into clean technologies
and clean energy R&D, demonstration,
deployment and uptake.
The carbon price is being introduced in
a two-step process, starting with a fixed
price period that runs from 1 July 2012
to 30 June 2015 before transitioning to
an emissions trading scheme. In the
fixed price stage the carbon price will
start at Australian dollar (AUD) 23 per
tonne and rise by 2.5 percent a year in
real terms. From 1 July 2015 onwards,
the price will be set by the market, with
the number of permits issued by the
government each year to be capped. The
carbon price was passed by parliament
on 8 November 2011 and commenced
on 1 July 2012.
Australian Renewable Energy
Agency (ARENA)
ARENA is tasked with managing
AUD3.2 billion of financial assistance
for renewable energy projects and
initiatives promoting the R&D,
demonstration, commercialization
and deployment of renewable energy
projects. The availability of this
funding is expected to improve the
sector’s long-term competitiveness
and drive down its costs in an
Australian context. Approximately
AUD2.2 billion of ARENA’s funding
is currently uncommitted and will be
available to support future projects
in the renewable energy sector.
ARENA incorporates and has
responsibility for overseeing
renewable energy initiatives previously
administered separately through a
range of bodies including the Australian
Centre for Renewable Energy (ACRE),
Solar Flagships Program, Australian
Solar Institute (ASI), Low Emissions
Technology Demonstration Fund,
Renewable Energy Demonstration
Program,RenewableEnergyVenture
Capital Fund, Australian Biofuels
Research Institute, Geothermal Drilling
Program and the Second Generation
Biofuels Research and Development
Program. ARENA also has accountability
for administering unallocated funding.
Listed below are initiatives which are
currently open or in planning phases
where additional funding is expected to
be announced.
EmergingRenewablesProgram
(ERP)
The ERP is focused on supporting
renewable energy technology at the
development, demonstration and
supported commercial stages of the
innovation chain. Ultimately the aim is
to lower the cost of energy produced
by renewable energy technologies to
a point where they are better able to
compete with traditional fossil-fuel
technologies. Funding totalling AUD126
million is available under two categories:
• Projects – Offers funding for
renewable energy and enabling
technologies and products as they
move through the technology
innovation chain. The application
process is undertaken in two phases,
with funding allocations expected to
fall within the range of AUD2 million
to 30 million.
• Measures – Offers funding for
initiatives that involve a renewable
energy industry capacity building
activity, skills development activity
or a preparatory activity for an ACRE
Project. The application process
is undertaken in one phase and is
expected to fund up to AUD2 million,
with a maximum funding pool of
AUD10 million.
Of the total funding pool of AUD126 million:
• AtleastAUD40millionwillbe
allocated to assist the development
of renewable energy and enabling
technologies with the potential
to contribute to the generation of
large-scale base load power such
as wave, geothermal and enabling
technologies.
• AfurtherAUD26.6millionwillbe
allocated specifically to assist the
geothermal energy sector.
RegionalAustralia’sRenewables
(RAR)
ARENA has also launched a new
strategic initiative, the RAR program,
which aims to demonstrate the viability
of renewable energy in regional and
remote locations. It will support
the deployment of commercially
prospective renewable energy
technologies, both generation and
enabling, in off-grid and edge-of-grid
situations. The RAR program has
sought community consultation and is
expected to be formally launched in the
first half of 2013, with funding running
for two to three years.
9 | Taxes and incentives for renewable energy
RenewableEnergyVenture
CapitalFund
The Southern Cross Renewable
Energy Fund is a 13-year, AUD200
million venture capital fund, operated
bySouthernCrossVenturePartners.
The fund was established under the
Australian government’s AUD100 million
RenewableEnergyVentureCapitalFund
(REVC).Thegovernment’scontribution
has been matched by an additional
AUD100 million contributed by Softbank
ChinaVentureCapital.
With offices and staff located in
Sydney, Palo Alto and Shanghai, the
fund makes selected investments
in Australian renewable energy
companies, providing capital and
assisting with the management skills
they need to commercialize their
technologies and succeed in
domestic and overseas markets.
Opportunities previously funded
by the ASI
ARENA has committed support for
programs previously administered by
the ASI, including the United States-
Australia Solar Energy Collaboration
Strategic Research Initiative as well as
solar Ph.D. scholars and postdoctoral
fellows following the success of ASI’s
Skills Development Program.
CleanEnergyFinanceCorporation
(CEFC)
The government has established the
CEFC through a financial commitment
of AUD10 billion to overcome capital
market barriers that hinder the
financing, commercialization and
deployment of renewable energy,
energy efficiency and low emissions
technologies. The CEFC will be
responsible for investing in firms and
projects that utilize these technologies
as well as manufacturing businesses
that focus on producing the inputs
required.
The CEFC began operations on 1 July
2013 and offers complementary
financing alongside private sector
financing for renewable energy and
clean energy enabling technologies.
Funding will be allocated over a period
of five years, with AUD5 billion for
renewable energy and technology
including geothermal, wave energy and
large scale solar power generation. The
remaining AUD5 billion will be allocated
to the general clean energy stream
which may also include renewable
energy.
The CEFC is intended to be
commercially oriented and make a
positive return on its investment. In its
early stages the CEFC will be offer loans
on concessional commercial terms,
with each agreement being considered
individually. As the fund matures, the
CEFC may choose to offer alternate
funding arrangements, including
mezzanine finance and other equity-
based funding arrangements.
EthanolProductionGrants(EPG)
The EPG program will support the
production and deployment of ethanol
as a sustainable alternative transport
fuel in Australia. The program provides
support via a full excise reimbursement,
at a rate of 38.143 cents per litre,
to ethanol producers for ethanol
produced and supplied for transport
use in Australia from locally derived
feedstocks. The program and grants
are administered by the Department of
Resources, Energy and Tourism.
R&DTaxIncentive
The major mechanism and program
for fostering innovation is a tax-based
scheme rewarding expenditure on
R&D activities. The R&D Tax Incentive
scheme is a broad-based program
accessible to all industry sectors. The
R&D scheme has recently undergone
a significant change, transitioning from
the R&D Tax concession to the R&D Tax
Incentive. In many instances, activities
conducted as a part of renewable
energy development may be eligible
for the R&D tax incentive. The program
offers two tiers of incentive based on
the turnover of the company in question:
• A45percentrefundabletax
offset (equivalent to a 150 percent
deduction) for eligible entities with a
grouped turnover of less than AUD20
million per annum.
• Anon-refundable40percenttaxoffset
(equivalent to 133 percent deduction)
for all other eligible entities. Unused
non-refundable offset amounts may
be able to be carried forward to future
income years.
The R&D Tax Incentive is an entitlement-
based, self-assessment program.
Registration of activities, via the R&D
application, is required within 10 months
of the relevant financial year end.
Operating subsidies
Feed-intariff
There are no national based feed-in
tariffs. However, a number of state-
based initiatives exist for small-scale
generation. The Australian Capital
Territory (ACT) has a Large Scale Feed-
in Tariff Scheme (the Scheme) which
provides the ACT government with
power to grant feed-in tariff entitlements
up to 210 MW of generation capacity.
The first tranche of capacity released
under the ACT provided industry with
an opportunity to compete for the
establishment of up to 40 MW of solar
generation (minimum 2 MW generating
system capacity). Applications for the
40 MW tranche are closed, but further
tranches are expected.
Quota obligation
20 percent by 2020.
Additional information
In addition to the funding initiatives
described above, the government
also has a number of policy levers and
numerous other programs.
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Taxes and incentives for renewable energy | 10
Austria
35
For applications filed in 2012
Support schemes
Investments and other subsidies
Small solar plants
Less than 5 kWp investment subsidies
are granted for the plants, sufficient for
them to achieve a six percent capital
yield.
Waste liquor plants
Maximum 30 percent of the investment
(not including real estate costs)
• upto100MW:EUR300/kW
• 100MWto400MW:EUR180/kW
• morethan400MW:EUR120/kW
Small hydro plants
• maximum30percentofthe
investment for 500 kW capacity:
up to EUR1500/kW
• maximum20percentofthe
investment for 2 MW capacity:
up to EUR1000/kW
• maximum10percentofthe
investment for 10 MW capacity:
up to EUR400/kW
• inbetweenthesesetpercentages,
the maximum is calculated via linear
interpolation.
Medium hydro plants (<10 MW)
• maximum10percentofthe
investment
• maximumEUR400/kWandmaximum
EUR6 million per plant
Operating subsidies
Feed-intariff
35
Wind energy:
• cents(ct)9.45/kWh
Solar:
In buildings:
• 5kWpto500kWp:ct18.12/kWh
In open space:
• 5kWpto500kWp:ct16.59/kWh
Geothermal:
• ct7.43/kWh
Sewage gas
• ct5.94/kWh
Landll gas
• ct4.95/kWh
Compact biomass (such as forest
woodchips or straw)
• ct8.9/kWhtoct14.00/kWh,
depending on the production
capacity (declining tariff)
Waste with high biogenic contingent
• Sameasforcompactbiomass,minus
25 percent
Liquid biomass
• ct5.74/kWh;surplusofct2/kWhfor
production in an efficient power-heat
cogeneration
Biogas from agrarian production
• ct12.93/kWhtoct19.5/kWh,
depending on the production capacity
(declining tariff)
Additional information
Legal
The feed-in tariffs are regulated by the
law for the promotion of electricity
production from renewable energy
resources (“Ökostromgesetz 2012”).
The concrete feed-in tariffs have to be
determined each year by a decree from
the Ministry of Economics.
Duration of the feed-in-tariffs
15 years for liquid and concrete
biomassorbiogas;13yearsforallother
renewable technologies.
Administrative procedures
Applications have to be filed with the
Renewable Energy handling Center
(“Ökostromabwickklungstelle,” http://
www.oem-ag.at/).
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11 | Taxes and incentives for renewable energy
Brazil
36
Producers and importers are legal entities that are beneficiaries of concessions or authorizations from the National Petroleum Agency (ANP). They are registered as
producers or importers of biodiesel in the Special Register held by the Brazilian Internal Revenue Service.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
Investments and other subsidies
Taxes over revenue and imports
(PISandCOFINS)
• aspecialtaxregimeisapplicablein
Brazil for producers and importers
of biodiesel,
36
which includes two
programs: the Social Integration
Program (Programa de Integração
Social or PIS) and the Contribution to
the Social Security Fund (Contribuição
para o Financiamento da Seguridade
Social or COFINS). The PIS and
COFINS taxes due are definitive,
meaning that the resale of biodiesel
by wholesalers, distributors and
retailers is not subject to PIS and
COFINS. Under this tax regime, the
producers and importers can opt for:
– a 6.15 percent PIS rate and a
28.32 percent COFINS rate
levied on gross revenues derived
frombiodieselsales;or
– a fixed value of PIS and COFINS
by cubic meter of commercialized
biodiesel Brazilian real (BRL) 26.41
and BRL121.59, respectively.
Producers opting for the fixed
value can obtain certain reductions
and exemptions of the amounts
due, depending on the supplier of
raw material or input applicable
to the production (for example,
acquisition from castor bean
producers or from family farmers).
Moreover, producers of biodiesel
under a non-cumulative regime
of PIS and COFINS are able to
offset 4.625 percent of presumed
credit on acquisition of inputs
from individuals or legal entities
that supply agribusinesses or
agribusiness cooperatives.
• Thesugarcanesalesforethanol
production are exempt from PIS and
COFINS, provided that the tax payer
is under the non-cumulative regime.
• Thereisaspecialtaxregime
for producers, importers and
distributors of ethanol. The producers
and importers may opt for:
– a 1.5 percent PIS rate and a
6.9 percent COFINS rate levied
ongrossrevenueofethanolsales;
– a fixed value of PIS and COFINS
by cubic meter of commercialized
ethanol – BRL8.57 and BRL39.43,
respectively, up to 31 August 2013.
Recently, the Brazilian government
edited Decree 7.997/13, which sets
forth that, from 1 September 2013,
the fixed value of PIS and COFINS
by cubic meter of commercialized
ethanol shall be increased to BRL21.43
and BRL98.57, respectively.
Despite this, the Brazilian government
enacted Provisional Measure 613
that grants to the producers and
importers a presumed credit in the
same values, which leads to a practical
effect of zero rate of PIS and COFINS.
Also, the taxpayers may opt for this
new fixed value and the presumed
credit in advance (from 8 May 2013).
When it comes to distributors of
ethanol, the options are (depending on
the option of the producer or importer).
– a 3.75 percent PIS rate and a
17.25 percent COFINS rate levied
ongrossrevenueofethanolsales;
– a zero rate for the fixed
PIS and COFINS.
• Ethanolsalescarriedoutbyretailers
and sales negotiated through the
Future & Commodities Exchange (Bolsa
de Mercadorias e Futuros or BM&F)
are not subject to PIS and COFINS.
FederalandstateVAT(IPIandICMS)
• Biodieselandethanolsalesare
not subject to the Industrialized
Products tax (Imposto Sobre
Produtos Industrializados or IPI).
• Equipmentusedintherenewable
energy generation process is
generally exempted from the IPI.
• TheStateValue-AddedTaxon
Sales and Services (Imposto Sobre
a Circulação de Mercadorias e
Serviços or ICMS) can possibly
be exempted for some products
used for biodiesel or ethanol
production. In addition, the ICMS
calculation basis may be reduced
for interstate operations related to
ethanol and biodiesel production
and distribution. This reduction
depends on individual state law.
• Inthesameway,operations
involving equipment used in the
generation of wind and solar
energy can possibly be ICMS tax-
exempt until 31 December 2015.
Contribution for Intervention in
theEconomicDomain(CIDE)
• Ethanolsalesarenotsubject
to Contribution for Intervention
in the Economic Domain
(Contribuição de Intervenção no
Domínio Econômico or CIDE).
Operating subsidies
Feed-intariff
Wind: N/A
Biomass: N/A
Hydro: N/A
Brazil currently has no feed-in tariff policy.
Taxes and incentives for renewable energy | 12
Additional information
Brazil is considered the world’s sixth
largest investor in renewable energy.
37
Nationwide, 44.1 percent of the Internal
Energy Supply (Oferta Interna de
Energia or OIE) is renewable,
38
whereas
the world’s average is 20.3 percent.
39
Furthermore, the National Bank for
Economic and Social Development
(Banco Nacional do Desenvolvimento
Econômico Social or BNDES) provides
a variety of financial programs
to stimulate the production of
renewable energy. The development
of the renewable energies in Brazil
is increasing, and almost half of the
energy consumed in Brazil is now
generated by renewable sources.
The actual scenario is very
advantageous for renewable energy.
The government expectations are that
renewable energy may be responsible
for 18 GW out of a total increase of
63 GW in the total installed capacity of
the segment over the next 10 years.
40
According to the Ministry of Mines
and Energy, Brazil is especially well
situated for becoming a major producer
of biodiesel. The country contains a vast
amount of arable land, much of which
has the right soil and climate for growing
a variety of oilseeds.
The growth of biodiesel as an alternative
energy source in Brazil is supported
by Federal Law 11.097/05, which
mandates a minimum of five percent of
biodiesel to be mixed with diesel and
the monitoring of this mixture in the
marketplace. This law also supports the
funding of R&D for biodiesel and other
energy sources, as well as all phases of
production, including the acquisition of
equipment and technology.
In a related matter, Brazil is one of the
most promising countries for wind
energy.
41
The first wind energy auction
was held at the end of 2009, in which
the government bought 1805 MW of
wind energy at a price of BRL148.39/
MWh. Encouraged by the success of
this auction, the government continues
to hold auctions on an annual basis.
Additional benefits not yet in force
Several other incentives being
discussed in the Brazilian scenario are
also worth mentioning:
The Brazilian Commission of
Infrastructure Services (CI) approved
PLS 311/09, a federal project law that
establishes the Special Regime of
Taxation to encourage the development
and generation of electric power from
alternative sources (Regime Especial
de Tributação para o Incentivo ao
Desenvolvimento e à Produção de
Fontes Alternativas de Energia or
REINFA). This project foresees several
tax benefits such as exemptions of
PIS and COFINS, import taxes and IPI
for companies operating under the
regime. It is important to emphasize
that this is not a law in force, yet. At the
present time, it is still awaiting internal
procedures in the Federal Senate.
After COP-15, Brazil formalized
its commitment to reduce carbon
emissions and increased its goal by
2.8 percent. Under the National Policy
on Climate Change (law 12.187/09),
Brazil has pledged to reduce carbon
emissions 38.9 percent by 2020.
According to this law, Brazil could grant
several tax benefits to encourage the
use of renewable energy. At this point in
time, these benefits have not yet been
implemented.
Recently, the government announced
the creation of a program of incentives
to the ethanol sector. This program
involves several benefits to this market
that will be implemented soon:
• CreationofalineofcreditofBRL6
billion for the production and storage
of sugarcane and ethanol with
reduced interests.
• Increasingofthepercentageof
ethanol to be mixed with gasoline
from 20 percent to 25 percent.
• Reductionofchemicalinputcosts,
by diminishing the chemical industry
costs with the increasing of its PIS
and COFINS credits.
Finally, other general benefits that
are not specific to renewables may
apply, such as the Special Incentives
Program for Infrastructure Development
(Regime Especial de Incentivos para
o Desenvolvimento da Infra-Estrutura
or REIDI), SUDAM/SUDENE incentives,
and technology innovation. Each one
has its requirements for application and,
in some cases, depends on government
approval.
37
Global Trends in Renewable Energy Investment 2012 – UNEP
38
Energetic National Balance (Balanço Energético Nacional) 2012
39
United Nations Environment Programme – 2012
40
Brazilian government website, 2013
41
GLOBAL Wind Energy Outlook of 2012
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13 | Taxes and incentives for renewable energy
Canada
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
Federalinvestmentsandother
subsidies
The Government of Canada has
committed that Canada’s total
greenhouse gas (GHG) emissions be
reduced by 17 percent from 2005 levels
by 2020 and that 90 percent of Canada’s
electricity be generated from sources
that do not produce GHG pollution by
2020. Here is a summary of incentives
and grants that the federal government
has invested in support of these goals.
Income tax incentives
Accelerated Capital Cost Allowance
(ACCA)
Advantageous ACCA rates are available
for certain types of assets used for
clean energy generation and energy
conservation:
• Class43.1(30percentdeclining
balance basis) for certain clean energy
generation and energy conservation
equipment.
• Class43.2(50percentdeclining
balance basis) for certain equipment
described in Class 43.1 that is
acquired on or after 23 February
2005 and before 2020 that is used for
clean energy generation and energy
conservation and meeting higher
efficiency standards.
• Recentfederalbudgetscontinueto
expand the list of equipment that
qualifies for an ACCA. The current
eligible equipment includes:
– electricity
– high-efficiency cogeneration
equipment
– small hydroelectric facilities
– wind turbines
– fuel cells
– wave and tidal power equipment
– photovoltaic(PV)equipment
– equipment generating electricity
from geothermal energy
– equipment generating electricity
from eligible waste fuel.
– thermal energy
– active solar equipment
– district energy equipment that
distributes thermal energy from
cogeneration
– heat recovery equipment used
in electricity generation and
industrial processes
– ground source heat pump
equipment
– equipment generating heat
for industrial processes or
greenhouses, using an eligible
waste fuel.
– fuels from waste
– equipment that recovers landfill
gas or digester gas
– equipment used to produce
biogas through anaerobic
digestion
– equipment used to convert
biomass into bio-oil.
• The2013budgetproposestobroaden
the eligible equipment in Class 43.2
to include
– Equipment used to produce biogas
using pulp and paper waste and
waste water, beverage industry
waste and wastewater, and
separated organics from municipal
waste.
– A broader range of cleaning and
upgrading equipment used to
convert eligible gases (biogas,
landfill, digester) into biomethane.
Canadian Renewable and Conservation
Expense (CRCE)
To promote development and
conservation of sources of renewable
energy, many start-up expenditures on
renewable projects can be grouped in a
CRCE pool. CRCE can include intangible
expenses such as feasibility studies,
negotiation, regulatory, site approval
costs, site prep and testing, etc. CRCE
can also include test wind turbines that
are part of a wind farm, on projects
where 50 percent or more tangible
costs are reasonably expected to be
included in Class 43.1 or 43.2 ACCA.
CRCE is fully deductible in any year, can
be carried-forward indefinitely or can
be transferred to investors through the
flow-through share rules.
Scientific Research & Experimental
Development (SR&ED) Program
The SR&ED Program is a federal tax
incentive program administered by
the Canada Revenue Agency that
encourages Canadian businesses of all
sizes, and in all sectors, to conduct R&D
in Canada. Companies, including those
carrying on business in clean energy
generation, may be entitled to claim an
Investment Tax Credit (ITC) if they incur
eligible R&D expenditure. The tax credit
is based on money already committed
and spent by the company. The program
is the single largest source of federal
government support for industrial R&D,
returning as much as a 35 percent
federal cash refund.
Sustainable Development
Technology Canada (SDTC)
SDTC plays a significant role in
bridging the gap between research
and commercialization of clean
technologies. It does this by fast-
tracking clean technologies through
their development and demonstration
phases, in preparation for
commercialization. SDTC is an arm’s-
length foundation that was created
by the Federal government to invest
Canadian dollar (CAD)1.09 billion in
innovative technologies and projects
that deliver economic, environmental,
and health benefits to Canadians.
Taxes and incentives for renewable energy | 14
Backed by CAD590 million in funds,
SDTC supports projects that address
climate change, air quality, clean water
and clean soil. The CAD500 million
NextGen Biofuels Fund supports the
establishment of first-of-kind, large
demonstration-scale facilities for
the production of next-generation
renewable fuels.
SDTC acts as the primary catalyst in
building a sustainable development
technology infrastructure in Canada. The
SDTC portfolio is currently comprised
of 245 clean technology projects, for a
total value of CAD2.1 billion, of which
over CAD1.5 billion is leveraged primarily
from the private-sector. In February
2013, SDTC announced its 22nd call
for applications, which was open until
17 April 2013
ecoENERGY
The ecoENERGY program targets
several areas including biofuels, energy
efficiency and renewable energy.
• ecoENERGYforbiofuels:The
ecoENERGY for Biofuels initiative
has a budget of CAD1.5 billion
over nine years to boost Canada’s
production of biofuels. The program
runs from 1 April 2008 to 31 March
2017, and recipients will be entitled
to receive incentives for up to seven
consecutive years.
• ecoENERGYforRenewablePower:
The ecoENERGY for Renewable
Power initiative has a budget of
approximately CAD1.4 billion over
14 years to encourage using
renewable energy sources to create
electricity. The program runs from
1 April 2007 to 31 March 2021. There
are no new agreements signed
after31March2011;however,many
projects with existing contribution
agreements will still receive
payments up until 31 March 2021.
Provincialinvestmentsandother
subsidies
Bioenergy Producer Credit Program
– Alberta
To expand Alberta’s bioenergy sector,
the Bioenergy Producer Credit Program
was established to provide production
subsidies for a variety of bioenergy
products, including renewable fuels,
electricity, and heat using waste
such as manure and wood chips. In
the 2013 budget, the Government of
Alberta cancelled future rounds of the
Bioenergy Producer Credit Program.
However, the government will still be
honouring payments to existing grant
agreements. The program is valid for
bioenergy production from 1 April 2011
to 31 March 2016.
Carbon Capture and Storage (CCS)
fund – Alberta
The Alberta government has
committed CAD2 billion to advance
CCS technology. Approved projects can
receive a maximum of 75 percent of
the total incremental cost to capture,
transport and store CO
2
. A maximum
of up to 40 percent of the approved
funding will be distributed during
the design and construction stage
based on achieved milestones and
up to an additional 20 percent of the
approved funding will be granted upon
commercial operation. The remaining
40 percent of the funding will be
provided as CO
2
is captured and stored
over a maximum period of 10 years.
The government of Alberta has awarded
funding for two projects from its CAD2
billion CCS fund.
• AlbertaCarbonTrunkLine(CAD495
million)
• ShellQuest(CAD745million)
Innovative Energy Technologies
Programs (IETP) – Alberta
The Innovative Energy Technologies
Program (IETP) supports the Provincial
Energy Strategy (PES), which identifies
the need for innovation, research and
technology development. Announced
in 2004, the IETP supports innovative
technology development in the
production of Alberta’s oil, oil sands, and
gas resources. It also supports finding
commercial technical solutions to the
gas-over-bitumen issue to allow the
efficient and orderly production of both
resources. Over time, program costs
will be recovered through additional
recoverable reserves and increased
royalties. Successful applicants in the
program are provided with royalty
adjustments up to a maximum of
30 percent of approved project costs.
The industry must provide the remaining
70 percent or more of total project
costs. The total industry/government
commitment to important new
technologies, assuming full subscription
of the program, will be more than
CAD800 million.
Innovative Clean Energy Fund (ICE) –
British Columbia
The Innovative Clean Energy Fund
encourages the development of
new sources of clean energy and
technologies and supports pre-
commercial energy technology or
commercial technologies not currently
used in British Columbia. Since 2008,
there are 62 projects with a total
amount of CAD77 million that have been
approved throughout British Columbia.
SR&ED tax credit – All provinces
Variousprovincesproviderefundable
and/or non-refundable investment
tax credits (ITC) worth between
10 percent and 15 percent of annual
eligible expenditures (depending on the
particular province) for all corporations
that do business through a permanent
establishment situated in that province.
Eligible expenditures are generally those
that qualify for federal ITC purposes
and are generally capped at a maximum
annual credit.
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15 | Taxes and incentives for renewable energy
Operating subsidies
There are no feed-in tariffs and quota
obligations at the federal level but they
are implemented in some provinces.
Quota obligation – Alberta
The province of Alberta requires
facilities that emit more than 100,000
tonnes of GHG emissions a year to
reduce their emissions intensity by
12 percent as of 1 July 2007. Emitters
have four choices for compliance with
this emissions reduction target:
• makeimprovementstotheir
operations
• purchaseoffsetcreditsfromother
sectors that have voluntarily reduced
their emissions
• payCAD15atonneintotheClimate
Change and Emissions Management
Fund, an arm’s length organization
independent from the government
that invests the funds into initiatives
and projects that support emission
reduction technologies
• purchaseEmissionsPerformance
Credits from facilities that have
reduced their emissions intensity
below the mandatory 12 percent
threshold.
Feed-intariff(FIT)–Ontario
The Ontario FIT program is North
America’s first comprehensive
guaranteed pricing structure for
renewable electricity production, and it
provides a way to contract for renewable
energy generation. It includes
standardized program rules, prices
and contracts for anyone interested
in developing a qualifying renewable
energy project. Prices are designed
to cover project costs and allow for
a reasonable return on investment
over the contract term, and they are
subject to review periodically. Qualifying
renewable technologies include biogas,
renewable biomass, landfill gas, solar
photovoltaic(PV),waterpowerand
wind power. As of 31 January 2013,
there were 1,728 contracts executed to
generate 4,546 MW of electricity.
With the help of the FIT program,
Ontario is on the track to be the first
jurisdiction in North America to replace
coal-fired generation with cleaner
sources of power by the end of 2014.
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Taxes and incentives for renewable energy | 16
China
Support schemes
Investments and other subsidies
Corporate Income Tax (CIT)
• AreducedCITrateof15percentis
granted to qualified advanced and new
technology enterprises. Applicable
fields include solar energy, wind energy,
biomaterial energy, and geothermal
energy.
• TheCleanDevelopmentMechanism
(CDM) Fund is exempted from CIT on the
following income:
– the portion of Carbon Emissions
Reductions (CERs) proceeds that are
shared by the government
– donations from international
financial organizations
– interest income derived from
capital deposit or national bonds
– donations from domestic and foreign
entities or individuals.
• EnterprisesoperatingCDMprojects
are allowed to deduct before CIT the
CER proceeds that are shared by the
government.
• ThreeyearsCITexemptionisfollowed
by a 50 percent reduction for another
three years of the standard CIT rate
for income derived from specified
CDM projects. These projects
include hydrofluorocarbons (HFC),
perfluorocarbons (PFC), and nitrous
oxide (N2O) projects, starting from
the year in which the revenue from
the transfer of greenhouse gas (GHG)
emission reductions is first received.
According to the new Administrative
Measures Governing the Operation
of CDM Projects in 2011, any project
companies, except for the 41 state-
owned enterprises listed, shall apply for
approval with the National Development
and Reform Commission (NDRC) at the
provincial level first. Then the commission
would submit preliminary review
opinions to the central NDRC for further
review. (According to the Old Measures,
all CDM project companies applied
directly to the central NDRC for approval.)
The New Measure also changes the
sharing percentage in the proceeds
from the transfer of emission reductions
units between the government and
companies involved in N2O and PFC
projects.
• ThreeyearsCITexemptionisfollowedby
a 50 percent reduction for another three
years of the standard CIT rate for income
derived from qualified environmental
protection and energy or water
conservation projects. This reduction
starts from the year in which the first
revenue is generated. Applicable fields
include biomaterial energy, synergistic
development and utilization of methane,
and technological innovation in energy
conservation and emission.
• Tenpercentoftheamountinvestedinthe
qualified equipment is credited against
CIT payable for the current year, with
any unutilized investment credit eligible
to be carried forward for five tax years.
This applies only if such equipment is
qualified as special equipment related
to environmental protection, energy,
or water conservation and production
safety.
• Only90percentoftherevenuederived
from the transaction is taken into account
for CIT computation purposes. This
applies only if such revenue is derived
from the use of specific resources
associated with the synergistic utilization
of resources as raw materials in the
production of goods.
• A150percentdeductionisgivenfor
qualified R&D expenses incurred for CIT
computation purposes.
Value Added Tax (VAT)
• 50percentrefundofVATispaidonthe
sale of wind power.
• 100percentrefundofVATispaidonthe
sale of biodiesel oil generated by the
utilization of abandoned-animal fat and
vegetable oil.
• VATpaidonthesaleofgoodsproduced
from recycled materials or waste
residuals is refundable.
• VATisexemptonthesaleofself-
produced goods including recycled water,
qualified powdered rubber made out of
obsolete tires, retrodden tires and certain
construction materials made from 30
percent or more of waste residuals.
• VATisexemptforsewagetreatment,
garbage disposal and sludge treatment
services.
In November 2011, the government
authority expanded the scope of sales of
self-produced goods/products by using
the prescribed recycled materials, waste
residuals and agricultural residuals that are
eligibleforVATrefundatratesrangingfrom
50to100percentoftheVATpayable.The
rates may vary depending on the nature of
recycled materials or residuals utilized.
As of 1 April 2013, the taxpayer is further
required to meet the local/national pollutant
emission requirements in order to receive
theVATincentiveforself-producedgoods/
products from recycled materials.
Vehicle and Vessel Tax
As of 1 January 2012, qualified energy
efficient vehicles and vessels enjoy a 50
percentVehicleandVesselTaxdeduction.
Qualified new energy (mainly electric)
vehicles and vessels may be exempted
fromVehicleandVesselTaxes.
Financialsubsidiesandtaxincentives
available to energy performance
contracting(EPC)projects
• Financialsubsidiesaregrantedbythe
central and provincial government
agencies respectively. The standard rate
of subsidies at the central level is Chinese
yuan (CNY) 240 per ton of standard coal
saved. The standard rate at the provincial
level is no less than CNY60 per ton of
standard coal saved. The NDRC and
Ministry of Finance jointly announce
the qualified energy service companies
(ESCO). These companies can apply for
financial subsidies on energy preservation
management contracts. The list of
qualified ESCOs is updated on a regular
basis. These financial subsidies are rolled
out under the jurisdiction of Energy
Performance Contracting (EPC), and they
should be taxable for CIT purposes.
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17 | Taxes and incentives for renewable energy
• AqualiedESCOtakingpartinanEPC
project will be eligible for a tax exemption
in the first three years and a tax reduction
by half (an effective rate of 12.5 percent)
over the following three years, starting
from the tax year in which the revenue
from the project first arises.
• Anenterprisethatinvestsinspecial
equipment for energy conservation will
obtain a credit against its tax payable
that equals 10 percent of the investment
amount in the year in which the
investment is made. Where there is not
sufficient tax payable to absorb the credit
in the year, the excess credit may be
carried forward up to five tax years.
• AqualiedESCOtakingpartinanEPC
project will be provisionally exempt
fromtheBusinessTax/VATonrevenues
received from the project.
• AqualiedESCOtakingpartinanEPC
project will be provisionally exempt from
theVATonthetransfertotheenergyuser
of goods related to the project.
• When,attheendofthetermofthe
energy management contract (EMC),
the ESCO transfers to the energy user
the assets that have materialized in the
course of executing the EPC project, the
ESCO can do so as if these assets had
been fully depreciated or amortized for
CIT purposes. In the same way, when
the energy user receives the project
assets from the ESCO, the energy user
can do so as if these assets had been so
depreciated or amortized.
• WhentheESCOtransferstheproject
assets to the energy user at the end of
the term of the EMC, the ESCO will not
have to recognize any revenue to take
into account the contributions the energy
user has made to the price of the assets.
• AnenergyuserinanEPCprojectcan
deduct reasonable expenses actually
incurred in accordance with the EMC
as, and when, they are incurred for
CIT purposes. There is no need to
differentiate between service fees and
asset prices in claiming such a deduction.
Operating subsidies
Feed-intariff
With the revised Renewable Energy Law
that came into effect in April 2010, the State
Bureau of Energy and other departments of
the State Council will promulgate guidelines
on the full purchase of electricity generated
by new energies. According to the revised
law, the price of on-grid electricity generated
by renewable energies shall be determined
by the competent price department of the
State Council. The council will consider
the difference in areas and the electricity
generated by different types of renewable
energy companies.
Financialfunds/allowance
Special funds are made available to facilitate
the development of renewable energy
relating to the following activities:
• scienticandtechnicalresearch,
standardization processes and model
engineering projects
• renewableenergyprojectsinruraland
pastoral areas
• constructionofstand-aloneelectricity
generation system in remote areas and
islands
• renewableenergyresourcesurveys,
evaluation and construction of
information systems
• localizationofmanufacturingfacilities
used in the renewable energy sector.
The special funds may also be deployed as
compensation for the higher costs charged
by renewable energy plants and indirectly
borne by the grid for the purchase of
electricity from these plants. Applicants may
apply for such funds with the local finance
bureaus and the government agencies in
charge of renewable energy projects.
Financialsubsidiesforenergy
conservation technologies improvement
During the State’s 12th Five-Year Plan
period, the central government will continue
to arrange special subsidies to support the
projects to improve the energy conservation
technologies.
In order to achieve optimum energy
conservation goals, the financial subsidies
are closely linked to the quantity of energy
conserved on a project basis. The project
companies shall be granted financial
subsidies if they fully complete the
expected goals of energy conservation.
For projects in the eastern regions of
China, companies may be granted a
one-time reward subsidy of CNY240 per
ton of standard coal based on the annual
energy consumption after the completion
of the projects. For projects in the central
and western regions of China, a one-time
reward subsidy of CNY300 per ton of
standard coal may be granted.
Financialsubsidiesforthedevelopment
of “Model County for Green Energy “
program
To promote the “Model County for Green
Energy” program, financial subsidies are
granted to the following qualified projects in
rural areas:
• concentratedprovisionofmethanegas
projects
• biomassgasicationprojects
• biomassbriquetteprojects
• otherprojectsthatdevelopandutilize
renewable energies
• ruralenergyservicesystem.
The amount of subsidies granted is subject
to a comprehensive evaluation with
reference to the completed investment
by the applicant, the level of green energy
productivity and the number of users.
Additional information
Quota obligation
The guidelines for quotas in the renewable
energy sector have been included in the
work plan of the State Bureau of Energy and
are expected to be issued by 2013.
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Taxes and incentives for renewable energy | 18
Denmark
Focusonrenewableenergyin
Denmark
The long-term target for Danish energy
policy is that the entire energy supply,
including transport, is to be covered
by renewable energy by 2050. This is
an ambitious target, and to pursue the
target, a number of sub-targets must be
achieved initially by 2020.
The targets for 2020 are the following:
• By2020,theCO
2
emissions must be
34 percent lower than in 1990.
• Theenergysupplymusthave
decreased by 12 percent compared to
2006.
• Approximately35percentofthe
energy supply must come from
renewable energy.
• 50percentoftheelectricity
consumption must be supplied by
wind power.
In addition, the general target is that,
as a whole, the terms and conditions of
the Danish business community – and
the energy sector in particular – must
remain stable.
The high ambitions mean that, in
Denmark, a strong focus is on energy
optimization and renewable energy.
Below, we describe some of the political
measures taken to achieve the above
targets.
Support schemes
Investments and other subsidies
Shift from fossil energy to renewable
energy
In Denmark, the primary fuels for
production processes include fossil
fuels such as natural gas and oil. Danish
politicians are committed to shifting
from fossil energy to renewable energy
by phasing out the use of fossil fuels
and replacing them with renewable
energy. However, this will not happen
overnight, and different incentives are
often needed to speed up the process
of change.
Therefore, it has been decided that
energy optimization projects supporting
the energy targets set should be
subsidized. The decision includes the
establishment of a pool of Danish krone
(DKK)500 million per year until 2020,
effective as of 1 July 2013. The pool for
2013 is DKK250 million. Depending on
company size, the possible subsidy is
45–65 percent of investment costs.
Projects that aim to replace fossil fuels
with renewable energy for production
processes are eligible for investment
support from this pool. In addition,
projects that aim to replace fossil fuels
with district heating for production
processes are also eligible for
investment support from the pool.
The support received per project
may not exceed EUR7.5 million as
the support is comprised by the EU's
General Block Exemption Regulation.
However, the above support is received
on the condition that no other operating
support is received for the project.
We believe that many Danish
enterprises will use this opportunity
to receive support for projects
aimed at replacing fossil fuels with
renewable energy — in particular, those
enterprises that already have or wish
to have a green profile. We also believe
that the support scheme will make it
possible to complete projects where the
profitability is uncertain.
Solar cells
With easy access to the sea, Denmark’s
renewables focus is still on wind energy
and offshore wind farms. However,
other types of renewable energy such
as solar energy are becoming more
popular.
In order to support the use of solar cells
in private homes as well as in business
enterprises, support schemes have
been introduced that are now being
discussed by the Danish parliament.
Basically, these support schemes offer
a guaranteed price for the electricity
generated that is sold to the public
power grid, typically over a 10 year
period. After this period, the electricity
generated can be sold to the public
power grid at market price.
The following support schemes are
expected:
• Sharedsolarpanelsinstalledon
rooftops in, for example, housing
associations
– DKK1.45/kWh for 10 years if the
solar panel system is connected to
the public power grid in 2013
– the subsidy decreases by DKK0.17/
kWh per year between 2014 and
2018, depending on the date of
grid connection. This means that
if the solar panel system is not
connected until 2014, the subsidy
will amount to DKK1.28/kWh for
10 years.
• Sharedsolarpanels,suchasthose
in housing associations, which are
not installed on rooftops but in other
areas such as the ground
– DKK0.90/kWh for 10 years.
• Roofsystems
– DKK1.30/kWh for 10 years if the
solar panel system is connected to
the public power grid in 2013
– the subsidy decreases by
DKK0.14/kWh per year between
2014 and 2018 depending on
the date of grid connection. This
means that if the solar panel
system is not connected until
2014, the subsidy will amount to
DKK1.16/kWh for 10 years, etc.
• Solarpanelsystemsnotinstalledon
rooftops, such as those on the ground
– DKK0.60/kWh for 10 years and,
subsequently, DKK0.40/kWh for
the next 10 years
The phasing out of the subsidy means
that solar panel systems that are
connected to the public power grid
after 2018 will be eligible for a subsidy
of DKK0.60/kWh for 10 years and,
subsequently, DKK 0.40/kWh for the
next 10 years.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
19 | Taxes and incentives for renewable energy
The subsidy or the guaranteed price
only applies to the electricity generated
that is sold to the public power grid. If
the electricity generated is used for the
generating entity’s own consumption —
in the business enterprise, for example
— this energy supply will not be
eligible for subsidies. However, it will
be possible to save money because
no electricity charges and no power
grid tariffs will be payable. In addition,
savings can be achieved on Public
Service Obligation (PSO) contributions
and the price for power.
The increased subsidies only apply
to solar panel systems installed on
rooftops that have been established for
the purpose of covering the user’s own
consumption of power. Following the
introduction of differentiating subsidies
and the above condition regarding the
entity’s own consumption, the previous
limit of 400 kWh has been abolished.
The purpose of differentiating subsidies
is to equate the comparatively
inexpensive installation of solar cell
panels on the ground with solar cell
panels installed on rooftops, which is a
more expensive investment. Abolishing
the maximum limit of 400 kWh also
means that it will no longer be profitable
to divide solar cell systems in order to
receive subsidies.
Biogas
Denmark is an agricultural country,
which allows us to produce biogas
based on animal fertilizers (liquid
manure). As a consequence, it would be
natural to launch incentives to produce
energy based on biogas.
In the spring of 2012, a new political
agreement on energy was reached.
Under this agreement, users of
biogas receive a subsidy of DKK26/
gigajoule (GJ) and a subsidy of DKK10/
GJ. However, these subsidies will
not become available until they are
approved by the EU.
According to Act to Amend the Danish
Promotion of Renewable Energy Act,
certain rates have been changed. This
means that when power is produced
based on biogas, a fixed subsidy of
either DKK0.793/kWh or a variable
additional charge of DKK0.431/kWh is
granted.
Moreover, the above energy agreement
introduces an additional subsidy of
DKK0.26/kWh (converted from DKK26/
GJ) and DKK0.10/kWh (converted from
DKK10/GJ). The fixed subsidy and the
variable additional charge are adjusted
on the basis of 60 percent of the
increase of the net price index.
The additional charges of DKK0.26/kWh
and DKK0.10/kWh are reduced annually
by an amount corresponding to the
amount by which the price of natural gas
for the previous year exceeds any given
basic price of DKK53.2/GJ.
The additional total support of DKK0.36/
kWh is almost a doubling of the variable
support of DKK0.431/kWh. In our
opinion, this will definitely increase the
incentive for producing power based on
biogas.
It has not previously been possible
to receive subsidies for using biogas
for process purposes in business
enterprises. However, in order to
increase the incentive, a general
subsidy of DKK0.39/GJ will now be
introduced, which may be received
together with the subsidies of DKK0.26/
GJ and DKK0.10/GJ granted for any use
of biogas. This also applies to biogas
used for transport, which was previously
also not eligible for subsidies. In this
area, the same support applies to the
use of biogas for process purposes in
enterprises.
Additional information
The above support and subsidy
schemes aim at increasing the incentive
for using renewable energy for the
production of energy for resale. These
schemes can support our national
energy consumption and help Denmark
achieve its ambitious climate and energy
targets, first by 2020 and later by 2050.
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Taxes and incentives for renewable energy | 20
France
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
Investments and other subsidies
The accelerated tax depreciation has
not been renewed as of 1 January 2011.
However, companies can still apply a
declining-balance method to certain
equipment used to produce renewable
energy. This method, which is optional,
consists of multiplying the depreciation
rate for the straight-line method by a
coefficient determined by law, based
on the asset’s expected useful life. In
practice, when a company applies the
declining depreciation method at the
beginning of the depreciation period, it
can obtain tax depreciation higher than
the accounting depreciation.
Biofuels
Biofuels benefit from a partial
exemption of the internal tax on
petroleum products and of the
general tax on polluting activities to
compensate for the additional costs
arising from biofuel production. Biofuels
in gasoline include bioethanol and ethyl
tertiary butyl ether (ETBE). This partial
exemption is applicable for the period
between 2013 and 2015.
Research tax credit
Companies may be granted a research
tax credit on their environmental
investments if the expenses they
incur while carrying on such projects
correspond to research activities eligible
for this tax credit. The tax credit will
be equal to 30 percent of the eligible
research expenses that do not exceed
EUR100 million and to 5 percent for
the eligible R&D expenses exceeding
EUR100 million.
The research tax credit will be offset
against the corporate income tax
due during the year the expenses are
incurred. Any surplus tax credit will
constitute a receivable for the company
that can be used to pay the corporate
income tax for the three following years
and may be reimbursed afterwards.
Operating subsidies
Feed-intariff
Remuneration is available for electricity
produced from the following sources.
Wind
Onshore wind power plants: EUR0.082/
kWh for 10 years and between
EUR0.028/kWh and EUR0.082/kWh
for the next five years depending on
the location of the wind farms and the
hours of electricity production. The
Court of Justice European Union (CJEU)
is currently reviewing this tariff under
the EU State aid rules (a decision is
expected in July 2013).
• Offshorewindpowerplants:
EUR0.13/kWh for 10 years and
between EUR0.03 and EUR0.13/kWh
for the next 10 years, depending on
the location of the wind farms and the
hours of electricity production.
Solar
Due to several recent changes in the
law, different tariffs apply to photovoltaic
(PV)powerplants,dependingonthe
stage of development of the projects
(tariffs for the first quarter 2013):
• ground-basedPVpowerplants:EUR
0.8.18/kWh
• simpliedbuilding-integrated
generating facilities: EUR 0.1817/kWh
or EUR0.1727/kWh
• building-integratedgenerating
facilities: EUR0.3159/kWh,
EUR0.2764/kWh, EUR0.31.59/kWh
depending on the use and the power
of the plant
As of 1 July 2011, the above-mentioned
tariffs have been adjusted quarterly
by the Ministry in charge of energy,
depending on the number of grid
connection applications received by the
distribution system operators over the
previous quarter.
A bonus of five percent or 10 percent
applicable on the above-mentioned
tariffs can be granted for the
componentsofthePVsystemmadein
Europe.
Geothermal
• France:EUR0.20/kWh,inadditionto
an energy efficiency bonus of up to
EUR0.08/kWh
• Frenchoverseasdepartments:
EUR0.13/kWh, in addition to an
energy efficiency bonus of up to
EUR0.03/kWh.
Biomaterial (Biogaz)
• BetweenEUR0.0.8121and
EUR0.1337 /kWh, depending on the
power of the plant, in addition to
an energy efficiency bonus of up to
EUR0.04/kWh.
Hydro
• EUR0.0607/kWhinadditiontoa
bonus between EUR0.005/kWh
and EUR0.025/kWh for small power
plants, as well as a bonus of up
to EUR0.0168/kWh for electricity
produced during the winter
• EUR0.015/kWhforoceanhydraulic
energy (wave energy, tidal energy and
other hydrokinetic energy sources).
Biomass
• EUR0.043/kWhinadditiontoabonus
between EUR0.0771/kWh and
EUR0.1253/kWh depending on the
energy efficiency, the nature of the
resources used and the power of the
plant.
Électricité de France (EDF) and other
electricity distributors must purchase
the electricity produced by a renewable
energies producer at fixed tariffs and for
a minimum duration. For example, there
is a purchase obligation for EDF during a
15 year period for onshore wind power,
geothermal power, and biomaterial
power and a 20 year period for offshore
wind power, solar power (subject to the
date of the operational start up of the
facilities) and for hydro power. The tariffs
mentioned above correspond to the
tariff applied to the power plants located
in metropolitan France. Increased
tariffs apply with respect to Corsica and
overseas departments.
21 | Taxes and incentives for renewable energy
Additional information
Building and Construction
AuthorizationandPermission(BCAP):
The construction of a power plant is
subject to the issuance of a building
permit. However, solar power plants
(subject to certain conditions) and wind
turbines smaller than 12 meters are not
subject to the issuance of a building
permit. Specific authorizations exist for
hydro and biomaterial power stations.
In addition to the building permit, an
exploitation authorization issued by the
Minister of Energy is required for power
plants with an installed load/installed
power higher than 4.5 MW. For power
plants with an installed power lower or
equal to 4.5 MW, only a declaration is
required.
The French government launched
“invitationstotender”forPVprojects
with a capacity exceeding 400 kW in
2013. Bids can be submitted until
16 September 2013. The 400 MW
should be divided equally between
“innovative” ground-mounted solar
plantsandtraditionalroof-mountedPV
systems. The purpose of this tender is
to encourage development at degraded
sites rather than farmland, to take into
account the carbon footprint of the
project, and to encourage innovation and
research and development (R&D).
FortheinstallationofPV,theinvitations
to tender launched beginning in 2011 are
maintained.
Renewalofhydroelectricconcessions:
Pursuant to the liberalization of the
electricity sector decided by the
European Union (EU), the French
government launched bidding rounds
to renew before the end of 2015 the
concessions for 10 lots that represent
49 power structures/stations and two
power-increase systems with a total
power capacity of 5,300 MW.
The concessions due for renewal are
located in the Alps, the Pyrenees and in
the center of France. The hydropower
stations are currently run by EDF and
by a GDF-Suez subsidiary, the Société
Hydroélectrique du Midi.
According to a statement issued by the
French Ministry in charge of energy, the
selection will be made pursuant to the
following three criteria:
• Theenergeticefciencyofthebidders
to modernize the existing structures or
to create additional equipment.
• Thenancialremunerationtobepaid
to the State by the concessionaire,
since a capped royalty proportional
to the turnover made with the
hydropower stations will be paid
to the French State and to the local
authorities.
• Theprotectionoftheecosystems.
(The bidders shall especially respect
the commitments convention for
the development of a sustainable
hydroelectricity, signed on 23 June
2010).
Offshorewindenergy:
France has set a target plan for installing
6,000 MW of offshore wind energy by
2020 through a tender process.
In April 2012, the French government
announced an award of four offshore
wind farm development zones (2 GW
of offshore wind energy capacity).
On 16 March 2013, the French Energy
Regulatory Commission issued a second
tender for offshore wind farms with 1
GW of new capacity. The new tender is
split into two wind farms: one built off
the city of Le Treport in Normandy and
the other near the Noirmoutier islands
andtheIled’YeuislandsoftheVendee
department of the Pays de Loire along
France’s Atlantic coast.
The deadline for submission of bids is
on 29 November 2013. The result of the
new tender should be announced in
January 2014 with the construction and
commissioning phase of the project is
scheduled for 2021 to 2023.
The selection of the bidders will be based
on the following criteria:
• priceoftheelectricityproduced
• overallcharacteristicsoftheprojectsin
terms of industrial and social aspects
• respectfortheenvironment
• considerationforexistingshing
activities.
The maximum price of the electricity to
be generated by the by new farms was
set at EUR220/MWh to avoid producing
“sticker shock” for consumers.
Gridaccess:
The producer/owner of a new power
plant has to apply for a grid connection
to the public distribution system such as
Réseau de Transport d’Electricité (RTE),
Electricité Réseau Distribution France
(ERDF) or a local distributing company.
Some agreements have to be made
by the owner of the power plant for
the distribution of the electricity that it
produces:
• publicgridcontract(Contratd’accèsau
réseau public)
• gridconnectioncontract(Contratde
raccordement)
• contractregardingtheuseofthe
equipment necessary for the grid
connection (Contract d’exploitation
des ouvrages de raccordement).
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Taxes and incentives for renewable energy | 22
Germany
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
KfWPrograms
KfW Renewable energies program
• Investmentsareavailableintwo
programs:
– Standard: in plants for electricity
generation from renewable
energiesphotovoltaic(PV),biogas,
hydro, onshore wind or geothermal
energy) and heat generation in
combined heat and power (CHP)
systems.
– Premium: in large plants for
heat generation from renewable
energies (solar panels, biomass,
biogas, deep geothermal energy)
as well as CHP installations
and heat networks/pumps not
promoted under the Standard
program.
• Premiumfundingwasinitiatedto
strengthen the establishment of the
renewable technologies in the heat
market (in the context of the Market
Incentive Program by the Federal
Ministry for the Environment). These
technologies include:
– solar panel systems with more
than 40 square meters gross
collector area for the purpose
of water heating and/or space
heating of properties with three
or more residential units or
non-residential properties with
minimum 500 square meters
of usable area
– biomass plants for the combustion
of solid biomass with a rated heat
capacity of more than 100 kW
– beat-controlled biomass CHP with
a maximum of 2 MW
– heat networks with a minimum
of 50 percent of heat generated
by renewable energies or with a
minimum of 20 percent of heat
generated by solar energy and with
heat sales of a minimum of 500
kWh per year and meter of route
– heat storages with more than
10 cubic meters
– biogas pipes with a minimum
length of 300 meters (for biogas
used for CHP purposes or as
biofuel)
– heat pumps with a rated heat
capacity of more than 100 kW
– facilities for the development and
use of deep geothermal energy
with a drilling depth of more
than 400 meters and a minimum
thermal fluid temperature of 20°C.
• Thefundingshallbegrantedasa
long-term, interest-reduced loan up
to 100 percent of the investment
costs(excludingVAT),maximumtotal
lending of EUR25 million per project
(Standard) and EUR10 million per
project (Premium).
• Additionalreducedinterestratesare
available for small to medium-sized
enterprises (Premium).
• Eligiblyforfundingdependsonthe
program part.
• In2012,KfWprovidedatotalcredit
volume of around EUR365 million
for Premium. Since initiating the
program, over 10 years ago, credit
volume over EUR2 billion for both
programs has been granted.
• Loan-term:5,10or20yearswitha
repayment-free, start-up period of up
to three years.
KfW offshore wind energy program
• Specialpromotionofoffshore
wind energy projects within the
12 nautical mile zone or the German
Exclusive Economic Zone (EEZ) of the
German North and Baltic Sea. Project
financing for up to 10 offshore wind
parks is available in the form of:
– direct loans granted by bank
syndicates (a maximum of
EUR400 million/project)
– finance packages comprising loans
from KfW on-lent through a bank
– direct loans limited to 70 percent
of the total debt capital required
per project and EUR700 million per
project
– direct loans to finance unforeseen
additional costs (a maximum of
EUR100 million per project).
• Eligibletoapply:allprojectcompanies
investing in the German EEZ or in the
12 nautical mile zone of the North Sea
and the Baltic Sea.
• Maximumfunding:EUR5billion.
• Loan-term:upto20yearswitha
repayment-free start-up period of up
to three years.
Incentives for energy efficiency and
corporate environmental protection,
housing, home modernization and
the reduction of carbon emissions
• Lowinterestratesonloansandgrants
used for the efficient production of
energy, usually accessed by SMEs.
• Subsidiesfornewprivatelyowned
buildings or buildings which are
brought to a new standard in
renewable energy or energy savings.
• Reducedinterestrates,abatementof
instalment payments on loans, direct
subsidies for modernizing buildings
and reducing carbon emissions.
• Budget:aroundEUR900millionfor
energy-efficient house modernization
in 2011.
Sources: KfW Bankengruppe, Berliner
Morgenpost (9 April 2011), BMWi
Förderdatenbank
Operating subsidies
Feed-intariff
Remuneration is available for electricity
produced. All tariffs and ranges apply
to plants commissioned in 2012. Plants
commissioned prior to 1 January
2012 are subject to the feed-in tariffs
that were in force in the year of first
commissioning.
23 | Taxes and incentives for renewable energy
Hydro
• Dependingonnominalgeneration
capacity of the individual plant:
– up to 5 MW: cent (ct)6.3/kWh to
ct12.7/ kWh
– more than 5 MW: ct3.4/kWh to
ct5.5/kWh.
• Degression:1percentperannum
(p.a.).
Biomethane
• Basicpremiumsdependingon
nominal generation capacity of the
individual plant: ct6.0/kWh to ct14.3/
kWh.
• Additionalpremiumsdependingon
the feed-stock boiled up to ct8/kWh.
• Usingthefermentationoforganic
waste, depending on nominal
generation capacity of the individual
plant: ct14.0/kWh to ct16.0/kWh.
• Additionalgaspreconditioningbonus
(up to ct3/kWh) for all above available
if nominal generation capacity of plant
does not exceed 5 MW.
• Usingfermentationofmanure:
ct25.0/kWh.
• Degression:twopercentp.a.
Other methane gas (mine, landll,
sewage sludge gas, etc.)
• Dependingonnominalgeneration
capacity of the individual plant: ct3.98/
kWh to ct8.60/kWh.
• Degression1.5percentp.a.
• Additionalgaspreconditioningbonus
for all the above (up to ct3/kWh).
Geothermal
• ct25.0/kWh.
• Degression:vepercentp.a.from
2018 onward.
• Additionalpremiumforusing
petrothermal technologies: ct5/kWh.
Wind
Onshore
• Basicfeed-intariffforawindturbine
(WT) commissioned in 2012: ct4.87/
kWh.
• Firstveyears:basicincreasedfeed-
in tariff of ct8.93/kWh.
• Increasedfeed-intariffforaWT
fulfilling technical requirements
for system intervention of the TSO
(“Systemdienstleistungsbonus”):
– ct0.48/kWh for the time the basic
increased feed-in tariff is received
and, if the newly installed WT is
commissioned before 31 January
2015.
• Degression:1.5percentp.a.,when
commissioned after 1 April 2012.
• Repoweringbonusofct0.5/kWhfor
the time the basic increased feed-in
tariff is received and granted for sites
where a WT with higher nominal
capacities are commissioned (pre-
degression). It is required that the
replaced WT was commissioned
before 1 January 2002.
• Directdistributionispossibleat
higher market rates, pursuant to Sec
33a-33f EEG.
Offshore
• Basic:ct3.50/kWh.
• First12years:ct15/kWh(extended
depending on water depth and
distance from shore).
• Degression:zeropercentp.a.
until2017;7percentp.a.from
2018 onward.
• Gridconnectionfromtheoffshore
switch station to the shore borne by
the TSO (Sec 17 par 2a EnWG).
If a WT has been commissioned before
1 January 2018, the plant operator can
claim a feed-in tariff of ct19/kWh for the
first eight years. This is not in contrast to
the regular feed-in tariff of ct15/kWh for
the first 12 years.
Solar
In and on buildings
• Dependingontheamountofnominal
generation capacity: ct11.02/kWh to
ct15.92/kWh as of April 2013.
• Degression:1percentpermonth
plus a maximum of 1.8 percent
points per month if a pre-defined
threshold of nominal generation
capacity added based on the annual
extension corridor (“Zubaukorridor”)
is exceeded, according to Sec 20a
EEG. The annual extension corridor
amounts to 2.5GW to 3.5GW. The
degression is adjusted on a quarterly
basis based on extrapolated annual
amounts of nominal generation
capacity added.
In open spaces
According to the Renewable Energy
Act, plants in open spaces are only
subsidized if they were erected in areas
being subject to an approved land-use
plan that has been:
• approvedpriorto1September2003
or
• approvedafter1September2003
where plants were erected either on
land to be devoted to different usage
(Konversionsfläche) or alongside
freeways (Autobahnen) or railroad
lines.
Up to a nominal generation capacity of
10 MW: ct11.02/kWh as of April 2013,
degression is equivalent to plants
erected on buildings.
Additional information
Legal:The feed-in tariffs are regulated in
the Renewable Energy Act (Gesetz für
denVorrangErneuerbarerEnergienor
Erneuerbare-Energien-Gesetz).
Durationoffeed-intariffs:Usually 15
to 20 years.
Administrativeprocedures:
Applications must be filed with
the Ministry of Environment or the
governmental-owned bank KfW.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Taxes and incentives for renewable energy | 24
India
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
Investment and other subsidies
Foreign Direct Investment (‘FDI’)
The growth of the clean energy sector in
India has been impressive. India permits
FDI up to 100 percent in the sector under
the automatic route in Renewable Energy
Generation and Distribution projects
that are subject to the provisions of the
Electricity Act of 2003. Under the Act, no
prior approval of regulatory authorities is
required.
Tax holiday under the domestic
income tax law
Undertakings engaged in the generation
and/or distribution of power has been
offered a 10-year tax holiday for renewable
energy plants if power generation begins
before 31 March 2014. However, the
plants have to pay a minimum alternative
tax at the rate of approximately 20 to
21 percent (based on the income), which
can be offset in future years (10 years).
It is likely that a new Direct Taxes Code
will be made effective as of 1 April
2014. The draft provisions of the Direct
Taxes Code provide for alternative
mechanisms for providing tax incentives
to power companies. As regards this
incentive, almost all revenue and capital
expenditures will be allowed as a tax
deduction upfront instead of claiming
amortization/depreciation on the capital
expenditure. In addition, there would be
no tax holiday.
Financing
The Indian Renewable Energy
Development Agency has been
established under the Ministry for
Non-Conventional Energy Sources as a
specialized financing agency to promote
and finance renewable energy projects.
Operating subsidies
Feed-intariff
Generation Based Incentives (GBI)
To attract foreign investors, the
government has taken several initiatives
such as introducing GBI schemes to
promote projects under Independent
Power Producers (IPP) mode for wind and
solar power.
Accelerated depreciation
Under the domestic income-tax law,
companies involved in renewable energy
such as solar and wind was provided with
accelerated depreciation at 80 percent.
However, the government has restricted
the accelerated depreciation of 80 percent
to windmills installed on or before 31
March 2012. Windmills installed after 31
March 2012 will be eligible for depreciation
of 15 percent instead of 80 percent on the
written-down value method.
It may be noted that 80 percent
depreciation is still available for solar
power projects.
Further, power companies have been
provided with an option to claim
depreciation under straight line method.
However, a company can claim either
accelerated depreciation or GBI (but not
both).
Quota obligations
Renewable Purchase Obligation (RPO)
The current contribution of renewable
energy is 12.5 percent of India’s total
generation installed capacity. The Ministry
of New and Renewable Energy estimates
that this contribution will increase to
around 16 percent or 17 percent by the
end of the 12th Five Year Plan in 2017.
RPO is one of the tools for implementing
this ambitious goal. Under RPO rules,
distribution companies, open access
consumers and captive consumers are
obligated to buy a certain percentage of
their power from renewable sources of
energy.Webelievethatgoingforward;
the enforcement of RPO will create the
volumes needed for the Renewable
Energy Certificate market.
Additional information
Jawaharlal Nehru National Solar
Mission (JNNSM)
The JNNSM is a transformational initiative
for solar energy development in India. Its
primary focus is to establish an enabling
environment for solar technology, both
at a centralized and decentralized level,
with 20,000 MW of grid-connected solar
power capacity by 2022.
Related to this initiative, the government
has launched the Payment Security
Mechanism for Grid Connected Solar
Power Projects and a Renewable Energy
Certificate Mechanism. The government
has also created the Amendment in
National Tariff Policy for enabling a solar-
specific Renewable Portfolio Obligation.
The JNNSM program has been designed
as a three-stage process with targets set
under each phase. Phase 1 (up to 2013)
will focus on capturing available options in
solarthermal;promotingoff-gridsystems
to serve populations without access
to commercial energy, and making a
modest increase in capacity to grid-based
systems. Under Phase 2 (2013-2017),
10,000 MW grid-connected solar plants
will be implemented, including rooftop
and other small-scale applications. For
off-grid solar applications, the cumulative
target for Phase 2 is 1,000 MW. Besides
the national program, solar programs at
the state level also exist.
The policy framework has generated
tremendous interest in this space, and the
response JNNSM program has received
from the market is overwhelming.
Carbon Credits and Clean
Development Mechanisms (CDMs)
The Clean Development Mechanism
(CDM) is an arrangement under the
Kyoto Protocol. The mechanism allows
developed (Annex 1) countries with
a green house gas (GHG) reduction
commitment to invest in projects
that reduce emissions in developing
countries as an alternative to more
expensive emission reductions in their
own countries. The developed country
gets carbon credits, while the developing
country gets capital and clean technology.
India is the second largest seller of carbon
credits. The country is also a leading
destination among non-Annex 1 countries
25 | Taxes and incentives for renewable energy
with regards to CDM implementation. It
has the highest rating of any CDM host
country, with 32 percent of the world
total of 1,081 projects registered with
CDM EB.
42
Tax and scal incentives
Tax cost forms a substantial part
of Engineering Procurement and
Construction (EPC) project costs,
which can range from 10 percent to
20 percent of the total renewable energy
project cost. Considering the special
focus on renewable energy, the Central
Government has given various incentives
on setting up the renewable energy
power project which includes exemption
from customs and excise duties on
specific goods required for setting up the
renewable energy projects.
However, these exemptions are subject
to the fulfilment of prescribed conditions
and compliances to be undertaken by the
EPC contractor or IPP.
Furthermore, some of the state
governments have provided the
incentivesintheformofaVATata
reduced rate (5 percent) whereas the
otherstateslevyaVATof15percent.
Given the vast variety of tax and fiscal
incentives available, one needs to quantify
the tax cost and explore the structuring
options before investing in the solar
sector.
Tax planning
For investors based overseas, an entry
strategy for India is highly important.
To achieve tax efficiency with regard to
taxability of gains on sale of shares, many
companies opt to route the investments
through an intermediate entity in a tax-
friendly jurisdiction.
Typically, renewable energy companies
in India procure equipment and services
from overseas. In this scenario, contract
structuring from a tax perspective helps
renewable energy companies to achieve
major tax efficiency upfront. In the case
of multiple parties coming together
and bidding as a consortium, contract
structuring is critical to avoid the risk of the
consortium being taxed as an Association
of Persons.
In India, based on the nature of
operation, different forms of entity can
be established. Operating through a
limited liability company by forming a joint
venture/wholly owned subsidiary could
be one of the possible options where the
foreign company is looking at a long-term
presence in India. However, one needs
to rule out other relationships and entities
before proceeding with these options.
In addition, the renewable energy
sector is capital intensive, so investing
companies need to carefully explore the
options available for funding their projects
and repatriating profits in a tax-efficient
manner.
EPC contracts
The taxation of EPC contracts offers
various challenges and opportunities.
The EPC contract can be structured as a
single contract or as divisible contracts.
The selection of either option can cause a
huge impact on the tax costs and working
capital of the project.
The selection of schemes for the payment
of indirect tax liabilities on renewable
energy power plant construction
offers various tax planning avenues
for renewable energy power projects.
Furthermore, any scheme can involve
difficulties in compliance, such as a
restriction on procurement of goods
outside the state.
The procurement of goods and supply
chain structuring play a vital role in the
solar power project costs, since the tax
rates are different for procurement of
goods from outside India, from other
states or from the same state.
Generally, the EPC contractor
also undertakes the operation and
maintenance of the power plant.
The taxability of an Operation and
Management (O&M) contract has
been the subject of disputes in various
decisions.
The exemption provided under the
Customs and Excise Act is subject to
various conditions and compliances.
Hence, it is very important to ensure the
compliance of the respective conditions
as otherwise the benefits envisaged may
not be available.
The proposed introduction of the Goods
and Services Tax will also play a major
role in the costing of a renewable energy
power project.
Given the vast variety of tax and fiscal
incentives available, one needs to quantify
the tax cost and explore the structuring
options, before planning the capex, at the
tender/bid stage and also at the time of
awarding contracts, so that tax costs are
optimized.
42
Point Carbon and UNFCCC
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Taxes and incentives for renewable energy | 26
Ireland
Support schemes
Investments and other subsidies
Corporate tax relief
Irish tax law provides tax relief for
corporate equity investments in certain
renewable energy projects. Commonly
known as Section 486B relief, the law
allows a deduction from a company’s
profits for its direct investment in new
ordinary shares in a qualifying renewable
energy project. There are a number of
conditions that must be satisfied for the
investment to qualify for the relief, and the
relief is capped at certain levels. Examples
of renewable energy projects that
would qualify for the relief include those
in the solar, wind, hydro and biomass
categories.
EII scheme
In 2011, the Irish government introduced
the Employment and Incentive
Investment (EII) scheme, designed
to promote the creation of jobs and
encouraging R&D activities. The EII
scheme provides tax relief for eligible
individuals who investment in certain
qualifying small and medium sized trading
companies. The relief takes the form of
a deduction from an individual’s taxable
income in the year of investment (subject
to certain restrictions), taken after a
three-year investment term has passed
(subject to certain conditions being met).
A number of conditions must be satisfied
for an investment to qualify under the
scheme. However, the legislation includes
some helpful provisions designed to
ensure that renewable energy projects
meet the qualifying criteria.
R&D tax credit
A company can claim an additional tax
credit of 25 percent on incremental
qualifying expenditure incurred on R&D
activities. Qualifying expenditure includes
expenses such as salaries, overhead,
materials consumed, etc. A tax deduction
is also available against the company’s
profits at 12.5 percent. This can result in
a 37.5 percent net subsidy for a trading
entity (12.5 percent corporation tax
deduction and a 25 percent R&D tax
credit). The tax credit can be used to
shelter a group’s corporation tax liability
or carried forward indefinitely to reduce
a company’s future tax liability. Where
there is limited or no current or preceding
corporation tax liabilities, a company may
claim to have any remaining credit offset
against current year payroll taxes.
Accelerated capital allowances
Companies are entitled to claim
accelerated capital allowances (tax
depreciation) of 100 percent for capital
expenditures incurred on the purchase
of certain energy-efficient equipment or
vehicles.
Operating subsidies
Quota obligation
Under an EU Directive, the Irish
government has an obligation to
ensure that, by 2020, 16 percent of all
energy consumed in Ireland across the
electricity, heat and transport sectors
is from renewable sources. The Irish
government has planned that the 16
percent overall target will be achieved by
40 percent of electricity consumed being
from renewable sources, 12 percent of
consumption in the heat sector being
from renewable sources, and 10 percent
of consumption in the transport sector
being from renewable sources.
Feed-inTariff
Ireland currently has two Renewable
Energy Feed in Tariff (REFIT) schemes
open for applications. The REFIT 2 scheme
applies to onshore wind, small hydro and
landfill gas. The REFIT 3 scheme applies
to biomass technologies. The schemes
operate by guaranteeing a minimum floor
price for supplies of energy generated
from renewable sources. The 2013
reference prices for the REFIT 2 and
REFIT 3 schemes are as follows:
REFIT2
Category Price
Onshore wind
(above 5 MW)
EUR69.235/MWh
Onshore wind
(equal to or less than 5 MW)
EUR71.664/MWh
Hydro
(equal to or less than 5 MW)
EUR87.455/MWh
Biomass Landfill Gas EUR85.026/MWh
REFIT3
Category Price
AD CHP (units less than or
equal to 500 kWe)
ct15.7/kWh
AD CHP (units of greater
than 500 kWe)
ct13.6/kWh
AD (non CHP) (units less
than or equal to 500 kWe)
ct11.5/kWh
AD (non CHP) (units of
greater than 500 kWe)
ct10.4/kWh
Biomass CHP (units less
than or equal to 1500 kWe)
ct14.6/kWh
Biomass CHP (units of
greater than 1500 kWe)
ct12.5/kWh
Biomass combustion
(non-CHP)
ct9.9/kWh for using energy crops
ct8.9/kWh for all other biomass
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27 | Taxes and incentives for renewable energy
The energy supplier is also entitled to
a balancing payment for every kWh
purchased from the generator. The
balancing payment under REFIT 2 and
REFIT 3 is fixed at EUR9.90/MWh. The
full EUR9.90/MWh is payable to the
supplier where the market payment
is equal to or less than the reference
price. If the market price exceeds the
reference price but is less than the
combination of the reference price
plus balancing payment, the balancing
payment shall be EUR9.90 less the
amount by which the market payment
exceeds the reference price. However,
where the market payment is equal to
or greater than the combination of the
reference price plus balancing payment,
no balancing payment is payable.
Additional information
Ireland as a hub for green asset
management
Global investment is booming in green
and clean-tech industries that produce
renewable energy, increase energy
efficiency or provide sustainability
solutions. Major investors include
pension funds, life funds, large
corporations and high net worth
individuals. These investors are attracted
to a variety of fund structures to diversify
the risk between different green
investments and different geographies.
With almost 25 years expertise
and experience, Ireland has one of
the most sophisticated investment
management industries globally. This
includes expertise in fund servicing,
administration and asset management.
Fund promoters are attracted to Ireland
due to its open, transparent and well-
regulated investment environment,
its strong emphasis on investor
protection, its efficient tax structure
(with a 12.5 percent corporate tax
rate) and its dynamic, innovative
business culture.
In addition to Ireland’s credentials as
a leading investment funds location,
the case for Ireland as a global center
for green asset management is even
more compelling. For many years a
large number of Irish companies have
successfully developed renewable
and sustainable projects and related
technologies on a global scale. As a
result, Ireland has been able to create an
unparalleled talent pool with the requisite
expertise to support green investments.
The combination of these two factors
sets Ireland apart.
A number of green investment funds
have established operations in Ireland
and all indications would suggest that
the scale of this activity will increase
considerably in the short to medium
term. A public private partnership body
known as the Green IFSC (GIFSC) has
been established to promote Ireland as
a center of excellence for green asset
management.
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Taxes and incentives for renewable energy | 28
Italy
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
Investment and other subsidies
Italy has a well-developed system
of incentives for renewable energy
generated from solar, wind and biomass.
In particular, the Ministerial Decree
of 5 July 2012 – which introduced the
so-called Fifth Energy Incentives Plan
– revises the system of incentives
for the production of electricity from
photovoltaic(PV)plants.Atthesame
time, the Ministerial Decree of 6 July
2012 establishes new procedures
aimed at supporting the production
of electricity from Renewable Energy
Source-Electricity (RES-E) plants (other
thanthePVones)withacapacityofat
least 1 kW. Under this Decree, such
plants must be “new, totally rebuilt,
reactivated, repowered/upgraded
or renovated plants which will be
commissioned on or after 1 January
2013” (More information at the Gestore
dei Servizi Elettrici website: gse.it).
To safeguard investments on projects
under completion, the Ministerial
Decree of 6 July 2012 provides that the
following plants may apply for support
on the terms and conditions specified in
the Ministerial Decree of 18 December
2008:
• Plantsauthorizedbefore11July2012
(the Decree’s enforcement date) and
commissioned by 30 April 2013
• Plantsauthorizedbefore11July
2012, fuelled by waste (as per article
8, paragraph 4C of the Decree) and
commissioned by 30 June 2013.
The feed-in tariffs granted or the
multiplicative factors for the green
certificates issued to these plants will
be decreased as indicated in article 30,
paragraph 1 of the Decree.
The Decree of 6 July 2012 also covers
the procedures under which plants
already in service and supported under
the Ministerial Decree of 18 December
2008 must pass in 2016 from the Green
Certificates scheme of incentives to
new support schemes as defined in the
Decree.
Operating subsidies
Feed-intariffpremiums
Solar
Solar plants that began operations
before 31 May 2011
• AccordingtotheMinisterialDecree
of 6 August 2010 (the Third Energy
Incentive) there is a fixed premium (a
bonus on top of the market price of
electricity).
• Thesizeofthepremiumdependson:
– type of plant
– nominal output
– when the plant started to operate.
• ThepremiumrangesfromEUR0.251/
kWh to EUR0.402/kWh.
• Thepremiumwillbepaidfor20years
after the plant starts operating. For
thermodynamic plants, the premium
will be paid for 25 years.
Solar plants that began operations
between 31 May 2011 and 31
December 2012
• AccordingtotheMinisterialDecree
of 5 May 2011 (the Fourth Energy
Incentive) a fixed premium computed
on the basis of the type and the
nominal power of the plant is available
up to 31 December 2012.
• Intherstsixmonthsof2012the
premium ranges from EUR0.148/kWh
to EUR0.274/kWh and in the second
six months of 2012 the premium
will range from EUR0.133/kWh to
EUR0.252/kWh.
• Thistypeofsubsidywillexpireon
31 December 2012.
• Thepremiumwillbepaidfor20years
after the plant starts operating, as
long as it does so by 31 December
2016. For thermodynamic plants, the
premium will be paid for 25 years.
Solar plants that began operations after
27 August 2012
• TheMinisterialDecreeof5July
2012 became effective on 27 August
2012 and introduced the Fifth Energy
Incentive Plan, thus redefining the
Italian incentive system for the
productionofPVenergy.
• Basedonthenewscheme,some
plants can still have access to
incentives granted under the Fourth
Energy Incentive Plan. In particular,
the Fourth Energy Incentive Plan shall
continue to apply to:
– Plants installed in public buildings
and areas owned by the Public
Administrations, commissioned
before 31 December 2012.
– SmallPVplantsintegratedinto
buildings with innovative features
(BIPV)andconcentratingPVplants
commissioned before 27 August
2012.
– LargePVplantsthatarepositioned
in the relevant Public Registers
as plants that do not exceed a
given applicable cost limit and
whose certificates of completion
are submitted for the registration
within seven months – or nine
months in the case of plants with a
capacity of above 1 MW – after the
publication of the related ranking
list.
• InaccordancetotheMinisterial
Decree of 5 July 2012, the incentives
fornewPVplantswillceaseand
therefore no longer apply once the
relevant total expenditure reaches
EUR6.7 billion.
• Inaccordancewiththenewtariff
system, the most important change
is that plants with a capacity not
exceeding 12 kW (including upgraded,
renovated, repowered plants with an
29 | Taxes and incentives for renewable energy
increase in capacity not exceeding an
overall capacity of 12 kW) now have
direct access to the feed-in tariff in
compliance with the procedures set
by the Manager of Electricity Services
(Gestore dei Servizi Energetici or
GSE). In the case of plants with a
capacity up to 20 kW, they may have
access to the same incentives upon
condition that a 20 percent tariff
reduction is accepted.
• InthecaseoftheFifthIncentivePlan,
the tariff scheme applies as follows:
– For plants with capacity up to 1
MW, a feed-in tariff applies based
on the electricity sold to the GSE.
– For plants with capacity exceeding
1 MW, a premium tariff is paid
based on the electricity generated
which is not sold to the GSE.
– For self-consumption, a special
tariff applies.
MinisterialDecreeof6July2012-
IncentivesawardedtoRES-Eplants
otherthanPVplants
Types of incentives
• TheMinisterialDecreeof6July2012
establishes that the support shall
be granted for the net electricity
generated by the plant and injected
into the grid. Therefore, self-
consumed electricity is not eligible for
incentives.
• Thenetelectricitygeneratedand
injected into the grid is the lower
value between the net electricity
generated and the electricity actually
injected into the grid by the plant.
• TheDecreeprovidesfortwoseparate
support schemes, based on plant
capacity, renewable source used and
type of plant:
– An inclusive feed-in tariff for plants
with a capacity of up to 1 MW.
This capacity is the sum of a
base feed-in tariff (whose value is
defined for each source, type of
plant and capacity class) and of any
premiums, such as high-efficiency,
emission reductions, etc.
– An incentive for plants with a
capacity of above 1 MW and for
those with a capacity of up to 1
MW not opting for the all-inclusive
feed-in tariff. This incentive is
the difference between the
base feed-in tariff – increased by
the premiums, if any, for which
the plant is eligible – and the
hourly zonal electricity price. The
electricity generated by plants
benefiting from the incentive
remains the property of the
producer.
• Accesstotheincentivesaccording
to the Ministerial Decree of 6
July 2012 is an alternative to net
metering (“scambio sul posto”)
and to simplified purchase/resale
arrangements (“ritiro dedicato”).
Feed-intariffs
• TheMinisterialDecreeof6July2012
identifies the value of the base feed-in
tariffs for each source, type of plant
and capacity class in the case of
plants commissioned starting from
2013. The tariffs will decrease by
2 percent in each of the subsequent
years until 2015, except in case of
failure to reach 80 percent of the
yearly capacity quota required for the
registries and the auctions.
• Thevalueofthebasefeed-intariffis
the one applicable upon the date of
the plant’s commissioning. The GSE
will award the all-inclusive feed-in
tariff or the incentive, calculated from
the value of the base feed-in tariff, as
of the date of entry into commercial
operation of the plant.
• Forplantscommissionedpriortothe
closing of the period of submission
of applications for participating in the
Registries or Auctions and whose
ranking position in the relevant
Registries does not exceed the
applicable cost limit, the GSE will
grant the base feed-in tariff applicable
upon the date of closing of the same
period.
• TheDecreealsoprovidesfora
number of premiums on top of
the base tariff for plants that meet
specific operating requirements.
Additional information
Limit on public expenditure to
support renewable energy:
The overall public expenditure should
not exceed EUR5.8 billion per year.
Authorization procedures:
To accelerate the overall authorization
process the Renewable Energy Decree
simplified the procedures for building
and operating renewable energy plants.
The new Single Authorization
procedure (Autorizzazione Unica or AU)
now takes only 90 days rather than
180 days. However, this period does
not include the time required for the
environmental impact assessment
(ValutazionediImpattoAmbientale).
The regulations that implemented the
Renewable Energy Decree identified
which “substantial modifications” to
a project require a new AU and which
modifications can be authorized by
following a simplified procedure.
The new provisions of the AU apply
to all authorization procedures that
started after the Renewable Energy
Decree came into force. Authorization
procedures that started before then will
continue to be subject to the previous
authorization procedure. The Renewable
Energy Decree also introduces a new
simplified authorization procedure for
small plants (the “PAS”). However,
where specific environmental or
landscape authorizations are required,
the AU procedure remains mandatory.
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Taxes and incentives for renewable energy | 30
Taxation:
Corporations are subject to IRES
(a corporate income tax) which is levied
at 27.5 percent and to IRAP (a regional
business income tax) with a rate that
varies from 3.9 percent to 4.82 percent.
Robin Hood Tax
Law Decree no. 138/2011 (the Mid-
August measure) sets out certain
significant changes to the corporate
income tax surcharge for the energy
industry (the so-called “Robin Hood
Tax”).
The Robin Hood Tax applies to the solar
and wind farm business if the following
thresholds are both exceeded in the
previous fiscal year:
• EUR10millionofgrossrevenues
• EUR1millionofcorporateincometax
base.
Such surcharge applies to companies
involved in the following business
activities:
• transmissionanddistributionof
electricity
• transportationanddistributionofgas
• productionofrenewableenergy
(biomass, photovoltaic, wind).
The rate of the surcharge has been
increased by 4 percent (i.e. from 6.5
percent to 10.5 percent) for fiscal years
2011, 2012 and 2013. As a result, the
aggregate Corporate Income Tax rate
which was applicable to companies
involved in the energy business and was
originally at 34 percent (27.5 percent
plus 6.5 percent) starting from fiscal
year 2009, is now fixed at 38 percent
(27.5 percent plus 10.5 percent) for years
2011, 2012 and 2013.
Non-operating or dormant
companies
The Mid-August Measure also
introduced the following changes to the
rules governing “dormant” companies,
to take effect as of 2012:
• anincreaseofIRESto38percentfor
companies that are considered as
dormant
• anextensionofthisruletocompanies
that have incurred in fiscal losses
(included in their tax returns) for three
consecutive years.
A company is considered dormant if
following applies:
• Itissubjecttoaminimumtax
charge as far as IRES and IRAP are
concerned.
• Limitsareineffecttotheoff-setting
orarefundrequestforanyVATcredit
accrued.
The minimum income level is calculated
by applying specific percentages
to certain balance sheet items. In
addition, a specific test is conducted
to determine whether a company is
dormant, comparing the actual values
reported in the statement of income
with presumed values. If the actual
values are below the presumed ones,
the company is deemed to be dormant.
Depreciation
Wind and solar plants are subject to
ordinary amortization/depreciation tax
rules.
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31 | Taxes and incentives for renewable energy
Japan
Feed-in tariffs (FIT) for renewable energy
became available in Japan in July 2012.
The feed-in tariff rate for solar energy
for the period up to March 2013 was
Japanese yen (JPY)42/1kW for the
operation period of 20 years. In order
to get the feed-in tariff, the applicant
is required to have the following
conditions:
1. The power plant development plan is
approved by the government.
2. The development plan applied for
interconnection to transmission line
with the electric power company.
Applicants who fulfilled these two
conditions by February 2013 were
awarded JPY42 feed-in tariff, which is
applicable without time limit. While
the approved development plan with
the feed-in tariff of JPY42/1kW was
accumulated to be 11,010 KW in the
period from July 2012 to February
2013, only 420 KW, i.e. less than four
percent of the approved plan, became
operational in the same period. The
feed-in tariff for the period from April
2013 was reduced by 10%, i.e. from
JPY42 to JPY37.8.
It is reported that some plans might
have been delayed due to the limited
supply of equipment. In addition, it also
is reported that some plans might have
received approval to secure JPY42 feed-
in tariff without a concrete investment
schedule. A plan with a concrete
investment schedule might have been
crowded out by the latter plans from the
interconnection discussions with the
electric power companies. A plan with
a concrete investment schedule is a
sound one, whereas the plans which are
merely for securing JPY42 FIT is not. As
the interconnection is physically limited,
such a crowding-out may have taken
place. As a result, the government may
want to review the approved plans for
their concrete development schedules.
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Taxes and incentives for renewable energy | 32
Mexico
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
Mexico’s Income Tax Law (ITL) provides
a 100 percent deduction incentive for
taxpayers who carry out investments
in renewable energy equipment.
Qualifying sources like sun, wind, water
and geothermal energies, as well as
biomass fuel equipment, are eligible for
this incentive.
Additional information
FIDE (Trust for energy saving) energy
efciency
Projects are funded for the installation
of new high efficiency technologies by
micro, small and medium enterprises,
municipalities, industries and service
sector companies. These technologies
are also tax deductible as investments.
The following equipment is included
in this program: air conditioners,
water pumps, air compressors, high-
pressuresodiumvapour(HPSV)lamps,
light-emitting diode (LED) lighting,
fluorescent compact lamps, electric
motors, renewable energy systems for
refrigeration, ventilation, speed control,
and other energy efficiency equipment.
Applicants must file a request for the
fund and be approved.
FIDE business eco-credit
Projects up to USD30,000 are funded
for replacing obsolete equipment
with high efficiency equipment. The
program applies to companies of any
size in the private sector. Besides the
funding, the companies are awarded a
10 percent scrapping bond. Technologies
financed under this program include air
conditioning, commercial refrigeration
systems, electric motors, LED lighting,
high efficiency lighting and electrical
substations. Applicants must file a
request for the fund and be approved.
Fund for hydrocarbon projects
In 2012, the Ministry of Energy (SE) and
the National Council of Science and
Technology (CONACYT) released a fund
oriented to R&D and the adoption of
new technology related to hydrocarbon
sources of energy. The fund aims
to increase efficiency in the use of
hydrocarbon sources of energy, prevent
pollution, and repair environmental
damages derived from the oil industry
activities. The official bid for 2012 called
for universities, research centers and
private entities to propose projects
related to exploration, production,
refinery and oil chemistry studies. No
bid has yet been published for 2013.
Fund for hydrocarbon projects
The Renewable Energies Exploit
and Energy Transition Financing Law
(LAERFTE in Spanish) allows industrial,
commercial and residential installation
of renewable technologies for the
generation of electricity for private
consumption only. According to Mexican
legislation, only the Electricity Federal
Commission (CFE) is allowed to sell
electricity. If the energy production
exceeds the amount used by an entity
during a given month, the excess can
be fed into the CFE’s grid and becomes
a credit that can be applied against the
entity’s electricity bills in the future.
The CFE will not reimburse the money
equivalent to the energy fed into the grid.
Fund for energy transition and
sustainable exploit of energy
In 2008, LAERFTE was released.
It establishes Mexico’s strategy to
support policies, programs, actions and
projects oriented to increase the usage
of renewable energy sources and clean
technologies, promote energy efficiency
and sustainability, and decrease oil
dependency as the main source of
energy.
To finance sustainability projects,
the Fund for Energy Transition
and Sustainable Exploit of Energy
was created in 2009. The Federal
Expenditure Budget for this fiscal
year assigned Mexican peso (MXN)3
billion (USD250 million) to the fund. For
fiscal year 2011, this amount has been
increased to USD260, based on the
Consumer Price Index (INPC).
Companies or individuals compete
for cash incentives from the fund by
submitting proposals for projects that
involve renewable energies and energy
transition. The announcement for 2010,
“Bioeconomy,” called for projects that
promote the production and use of
alternative fuels in primary sectors.
No bid was published for years 2011
and 2012, nor has a bid for 2013 been
published yet.
Fund for energy sustainability
Every fiscal year, the Ministry of Energy
(SE) and the CONACYT establish a
special fund for energy sustainability
projects in which universities and
research centers are the potential
participants and beneficiaries. The
resources for the fund are provided by
the Mexican Oil Company (PEMEX) and
are calculated every three months as
a percentage of their total income. The
projected balance for fiscal year 2011
is approximately MXN1 billion (USD84
million). After the official announcement,
participants will compete for cash
incentives by submitting their proposals
to the Committee, which will then
evaluate the proposals and decide on
the cash distributions. No official bid
was published during 2012, nor has a
public bid been published during 2013.
The fund for energy sustainability
supports four kinds of projects:
33 | Taxes and incentives for renewable energy
• Appliedresearch: research
regarding energetic sustainability
technology.
• Technologydevelopment:
universities and/or research centers
working together with enterprises
in technology development projects
such as pilot tests or prototyping.
In such cases, the enterprises
must provide at least 30 percent
of the resources for the project
development.
• Technologypackages:
documentation, business planning,
feasibility studies and other activities
designed to link universities
and/or research center projects
with an enterprise partner.
• Technologyassimilation:
universities and/or research centers
working together with enterprises
in order to introduce a current
developed technology into Mexico.
In such cases, the enterprises
must provide at least 30 percent
of the resources for the project
development.
Fund for R&D in energy
The CFE and the CONACYT created
a fund to provide resources for R&D
projects in the electric sector. The
distribution of resources was carried out
by a competition among participants,
and the CONACYT released one
program in 2010, which ended in
February 2011. This program involved
seven types of projects related to
specific categories such as ocean
waves, ocean currents, hydraulic
equipment, nuclear energy and the
measurement of gas emissions. No
official bids were published during 2012,
nor has a public bid been released for
2013.
Government projects funded for 2011
include the following:
• MunicipalStreetLightingNational
Program: For 2011, the Fund has
authorized MXN120 million (USD10
million) for the execution of projects
for energy-efficient street lighting.
• SustainableLightProgram:This
program aims to decrease the
energy consumption in homes by
substituting 45.8 million lights during
2011 and 2012. The first stage of the
program is to be concluded within
the first months of 2012. The second
stage aims to double the number of
lights by the end of this year.
• IntegralEnergyServicesProgram:
This program is designed to provide
a greater percentage of rural
populations in Mexico with electricity
through renewable energy and small-
scale energy generation. The program
will be supported by the Global Fund
for the Environment (GFE), the Bank
of Reconstruction and Promotion
(BIRF) and the National Committee for
Indigenous Towns Development (CDI).
• NationalSustainableEnergy
ExploitProgram: A review carried
out by the National Sustainable
Energy Exploit Program (PRONASE)
identified several areas in which
energy efficiency might be increased
over a medium to long-term period.
These areas include transportation,
lighting, industrial motors and
home equipment. PRONASE will
continue to define new strategies
to encourage the use of renewable
energy in these areas for Mexico.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Taxes and incentives for renewable energy | 34
TheNetherlands
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
Investment and other subsidies
The following schemes are applicable
for solar, wind, geothermal, hydro,
biomaterial and offshore technologies.
• Anadditionaldeductionof41.5
percent of the amount invested in
qualifying assets is available under
the Energy Investment Allowance
(Energie-investeringsaftrek or EIA):
– Investments must be included on
the Energy List (Energielijst) to be
qualifying assets.
– The maximum amount of
investment for which EIA can be
claimed per calendar year per
taxpayer is EUR118 million. Pro
rata calculation applies in the case
of transparent entities.
– The total amount of qualifying
investments must be more than
EUR2,300 per calendar year.
– A granted EIA will be revoked
partially or in full (added back to the
fiscal profit) on alienation of the
assets within a five-year period.
– No prior use of the asset that is the
object of investment is permitted.
– The EIA and the Environmental
Investment Allowance (see below)
cannot be applied simultaneously.
– Certain formal conditions apply to
requests for the EIA.
– The EIA is subject to a maximum
annual budget, to be determined
annually (EUR151 million in 2013).
Applicability: Not directly applicable to
renewable energy, although assets for
which this tax incentive is applicable
can be used as part of the production of
energy from renewables.
• Anadditionaldeductionisgranted
of up to 36 percent of the amount
invested in qualifying environmentally
friendly assets under the
Environmental Investment Allowance
(Milieu-investeringsaftrek or MIA):
– Depending on the asset, the
amount that can be deducted
from the fiscal profit is 13.5, 27,
or 36 percent of the investment
costs. The maximum qualifying
investment costs that are taken
into account are EUR25 million per
taxpayer per calendar year.
– Investments must be included on
the Environmental List (Milieulijst)
to be qualifying assets.
– The total amount of qualifying
investments must be more than
EUR2,300 per calendar year.
– A granted MIA will be revoked
partially or in full (added back to the
fiscal profit) on alienation of the
assets within a five-year period.
– No prior use of asset that is the
object of investment is permitted.
– The EIA and the MIA cannot be
applied simultaneously.
– Certain formal conditions apply to
requests for the MIA.
– The MIA is subject to a maximum
annual budget, to be determined
annually (EUR101 million in 2013).
Applicability: Not directly applicable to
renewable energy, although assets for
which this tax incentive is applicable
can be used as part of the production of
energy from renewables.
•
Freedepreciation/depreciation
at will is granted on qualifying
environmentally friendly assets
(Willekeurige afschrijving milieu-
investeringenorVAMIL):
– Investments must be included on
the Environmental List (Milieulijst)
to be qualifying assets.
– Free depreciation of up to 75
percent of the investment costs of
the qualifying asset is granted. The
maximum qualifying investment
costs that are taken into account
amount to EUR25 million per
taxpayer per calendar year.
– The total amount of qualifying
investments must be more than
EUR450 per calendar year.
– No prior use of asset that is the
object of investment is permitted.
– Certain formal conditions apply
to requests for the accelerated
depreciation.
– Free depreciation/depreciation
at will is subject to a maximum
annual budget, to be determined
annually (EUR24 million in 2013).
Applicability: Not directly applicable to
renewable energy, although assets for
which this tax incentive is applicable
can be used as part of the production of
energy from renewables.
• Capitalinvestedingreen funds
(appropriated funds invested in
environmentally friendly projects
or groene fondsen) is exempt from
personal income tax:
– A private investor will not be taxed
for capital invested in green funds.
– The maximum amount of invested
capital exempted on an individual
basis is EUR56,420.
– A tax credit will be granted of 0.7
percent of the invested capital,
with a maximum amount of
invested capital of EUR 56,420 on
an individual basis.
Applicability: Investments in green
funds.
35 | Taxes and incentives for renewable energy
Operating subsidies
Feed-intariff
As of 4 April 2013, the regulation for the
feed-in tariff (Stimulering Duurzame
Energieproductie or SDE+) for 2013 has
opened. This regulation includes the
following features:
• amaximumamountofEUR0.15/
kWh (or EUR1.035/Nm3 or EUR41.67/
GJ) for all types of renewable energy
such as wind, geothermal, solar
photovoltaic, biomass and hydro
• phasedopening
• a“freecategory”toenhance
investments in certain technologies
• feed-intariffgrantedforacertain
period (5, 12 or 15 years)
• amaximumsubsidyamountfor
the Netherlands, to be determined
annually (EUR3 billion in 2013).
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Taxes and incentives for renewable energy | 36
NewZealand
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
Investment and other subsidies
Schemes are applicable for solar, wind,
hydro and biomaterial energy sources.
Historically, renewable generation
projects may have qualified for free
allocation of carbon credits. Current
policy is that generation which results
in greenhouse gas (GHG) emissions
will incur a carbon cost under the
NZ Emissions Trading Scheme. This
includes geothermal generation.
Operating subsidies
Feed-intariff
Remuneration is available for electricity
produced.
Additional information
Operating incentives
Wind generation is required to be
bid into the market. However, it is
automatically dispatched, and the
generator receives the same pool
price as other dispatched generation.
Generation from all other renewable
sources is treated the same as
generation from carbon. The lowest bid
price is dispatched first.
37 | Taxes and incentives for renewable energy
Norway
Power suppliers
Total energy
market of
renewable energy
26,4TWh
Electricity
consumer
government
Producers of
renewable energy
Certificate
Certificate
Payment
Payment
Support schemes
Investment and other subsidies
Energy Fund
The state-owned corporation Enova is
the driving force for an environmentally
friendly energy conversion by private
and public enterprises. Enova’s main
commission is through the Energy Fund
that supports environmental change in
the use and production of energy. The
management of the Energy Fund is
governed by an agreement between the
Ministry of Oil and Energy and Enova.
In addition, Enova manages the EU
program (Intelligent Energy Europe) and
the International Energy Association
(IEA) program known as Energy
Technology Data Exchange (ETDE) in
Norway.
Enova offers financial support based on
defined programs for various renewable
energy and environmentally friendly
projects based on an application
principle. In 2012 the Energy Fund
supported 750 different projects within
energy effectiveness, conversion and
increased utilization of renewable
energy amounting to approximately
Norwegian krone (NOK)1.7 billion.
Other allowances
The General Tax Act includes regulations
regarding tax allowances known as
SkatteFUNN to support R&D project
costs. Under the SkatteFUNN scheme,
any type of business enterprise
engaged in R&D activities may apply to
the research council for tax allowances.
R&D projects under the SkatteFUNN
scheme are aimed at obtaining new
knowledge or technical skills that can
benefit the company in connection with
the development of new or improved
goods, services or means of production.
The total tax allowance may not exceed
NOK11 million per company per year.
Operating subsidies
Feed-intariff
There are no national-based feed-in
tariffs in Norway. However, there is a
green certificate scheme.
Premium
Green certicates
The issuance of green certificates is
an economic subsidy scheme that will
make it more remunerative to invest in
power production based on renewable
energy sources such as hydro, wind,
solar and bio energy. The scheme is
regulated by the Green Certificates Act.
The Norwegian government has
entered into an agreement with the
Swedish government establishing
a common green certificate market
for electricity that will contribute to
increased production of renewable
energy. Moving toward 2020, Sweden
and Norway will increase their power
production from renewable energy
sources with 26.4 TWh. Power plants
that are included in the scheme receive
green certificates that can be sold in the
Norwegian-Swedish green certificates
market. Power suppliers and certain
power users are required to purchase
green certificates for a share of the
electricity they sell or use.
The following power producers may
apply, subject to certain requirements,
for green certificate approval for whole
or parts of its production based on its
total production:
• power
plantsbasedonrenewable
energy sources and built after 7
September 2009
• hydroplantsgenerating1MWand
built after 1 January 2004
• existingrenewablepowerplantsthat
permanently increase their electricity
production with new construction
beginning on or after 7 September
2009.
Any entity that delivers power to end
consumers is obliged to purchase green
certificates, and it is the end consumer
who finances the scheme through
increased costs when invoiced for
usage. The green certificate scheme
is managed by the Norwegian Water
Resources and Energy Directorate.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Taxes and incentives for renewable energy | 38
Quota obligation
Starting in 2008, the Norwegian
emissions trading system for
greenhouse gas (GHG) emissions
expanded to include nearly 40 percent
of the emissions related to Norway. It is
also affiliated with the European system
for quotas. The Norwegian system
for quota obligation applies to GHG
emissions in Norway and to emissions
from activities on the Norwegian part of
the continental shelf.
The quota system applies to emissions
in connection with:
• energyproduction
• reningofmineraloil
• cokeproduction
• productionandprocessingofironand
steel including roasting and sintering
of iron ore
• productionofcement,lime,glass,
glass fiber and ceramic products, as
well as the production of paper, board
and pulp from timber or other fibrous
materials
• aviationactivities.
Any person engaged in any of the
activities mentioned above is required
to surrender allowances corresponding
to any emissions to which the duty
to surrender allowances applies.
The Norwegian Emissions Trading
Registry shall contain information
on the allocation, issue, holding,
transfer, surrender and cancellation
of allowances. An operator will by
30 April each year transfer a number
of allowances corresponding to the
volume of emissions for which reporting
is mandatory, generated by the
installation in the previous calendar year
to a specified settlement account in the
registry.
Additional information
Indirecttaxes: Indirect taxes are
used as a policy instrument to reduce
the consumption of products that are
detrimental to the environment.
CO
2
tax: Gasoline, mineral oil, gas for
inland usage and petroleum activities
are subject to a CO
2
tax. A CO
2
tax
related to petroleum activities shall
be paid per liter of oil and natural gas
liquids and per standard cubic meter of
gas burnt off or emitted directly to air
on platforms, installations or facilities
used in connection with the extraction
or transportation of petroleum on the
Norwegian continental shelf. The tax is
classified as a deductible operating cost
associated with petroleum activities,
which contributes to reducing the
ordinary tax and special tax actually paid
by the oil companies.
The CO
2
tax was reduced according to
the estimated emissions trading price
when the Norwegian emissions trading
system was introduced.
NitrousOxide(NOx)tax:The NOx tax
is calculated per kg for NOx emissions
generated during the production of
energy from the following energy
sources:
• propulsionmachinerywithatotal
installed capacity of over 750 kW
• motors,boilersandturbineswitha
total installed capacity of more than
10 MW
• aresonoffshoreinstallationsandon
facilities on land.
Enterprises that join the Environmental
Agreement on NOx are entitled to a
tax exemption from the date when
they joined. From the same date,
the enterprise will have a payment
obligation vis-a-vis the business sector’s
NOx Fund. According to the Participant
Agreement, affiliated enterprises will
develop a measure plan identifying
possible NOx reducing measures within
two years after affiliation.
The purpose of the plan is to identify
profitable measures the enterprise can
implement on its own accord, and to
identify cost-effective NOx reducing
measures whose implementation are
dependent on support from the NOx
Fund. As of 13 March 2012, a total of 995
enterprises, ships and rigs had joined
the Environmental Agreement on NOx
2011- 2017.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
39 | Taxes and incentives for renewable energy
Peru
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
Investments and other subsidies
Peru has not implemented subsidies,
but it has implemented certain tax
incentives for energy producers
producing energy on renewable
resources.
However, Peru has not implemented
feed-in tariff schemes, premiums
to renewable energy producers or
renewable energy quota obligation
to energy producers.
Additional information
Peru is a country with abundant natural
resources. However, which resources
are considered renewable is determined
only by a general consensus rather
than legal definitions. This consensus
appears to be changing, and some
resources like water, which was once
considered renewable, are no longer
considered as such.
Apart from issues related to water,
no clear tax policy exists that might
promote investment into renewable
energy. However, a number of benefits
can be identified in the Peruvian taxation
system.
Geothermic resources law:
The Peruvian government grants
30-year concessions to explore and/or
exploit aboveground and underground
geothermic resources that are not
hydrocarbon-based.
Income tax stability: Geothermic
concessionaires will be subject to the
30 percent income tax regime in force
at the time of signing the concession
agreement during the term of the
concession.
Income tax assessment: Geothermic
concessionaires having more than
one geothermic resource concession
agreement that may also perform
activities related to geothermic
resources and connected activities
shall individually and annually
assess their income tax liability
by each contract and activity.
If one of the contracts generates tax
losses that carry forward, such losses
could be offset against the profits
derived from another contract or
geothermic related activities.
Investments applied to a geothermic
resource concession agreement that
may not have reached the exploitation
stage can be accumulated with
the same kind of investment made
with another contract that may have
reached the exploitation stage. These
accumulated investments can be
amortized either on a production basis
or proportionally over a five-year period
on a straight line method.
Import of goods: Import of goods and
inputs required to exploit geothermic
resources under concession are exempt
from all existing or to be existed taxes
provided such goods or inputs were
included in the specific list approved by
the Energy and Mining Ministry.
Investment in generating electricity
through hydro-power and other
Renewable Energetic Resources
(RER): Electricity generation through
hydro, wind, solar, geothermic,
biomass, wave or tidal powers or other
RERs is subject to an annual maximum
20 percent accelerated depreciation
regime for Income Tax purposes.
Accelerated depreciation is applicable to
electricity plants entering into operation
as of 29 June 2008. Accelerated
depreciation is applicable to machinery,
equipment and building infrastructures
required for the installation and operation
of electricity plants generating power
through renewable resources.
Electricity generated with RERs is
considered when it is first delivered into
the electricity distribution network.
Early recovery of the Input VAT
derived by electricity generating
corporations: Concessionaires of
electricity-generating activities through
RERs are entitled to the early recovery
oftheInputVATpaidforcapital
expenditures, services and building
contracts directly related to the electricity
generating activities, provided they do
not enter into the productive stage.
Selective Consumption Tax (Impuesto
Selectivo al Consumo or ISC): The
ISC excise tax is applicable to the
consumption of fuels. Beginning
1 January 2008 and extending until
1 January 2016, the Peruvian government
has established a schedule for applying
a specific amount of Peruvian nuevo sols
(PEN) as an ISC on certain fuels such
as diesel 2, kerosene and others that
contain harmful contaminants like sulfur.
Taxes and incentives for renewable energy | 40
Poland
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
Investment and other subsidies
• Supportschemesareapplicable
for solar, wind, geothermal, hydro,
biomaterial and offshore technologies.
• Renewableenergyisexemptfrom
excise tax.
• Insomecasessolarphotovoltaic
modules cannot be subject to real
estate tax as other constructions.
(The planned act on renewable energy
sources might provide otherwise.)
• Agriculturetaxpayersmayclaima
refund of investment costs if the
investment relates to renewable
energy (up to 25 percent).
• SubsidiesandgrantsfromtheEU
Structural Fund in Poland or other
domestic institutions (for example,
the National Fund of Environmental
Protection and Water Management).
Currently the following sources of
financing for renewable energy projects
are available:
• TheNationalFundofEnvironmental
Protection and Water Management
(NFEPWM) has announced a schedule
of application rounds for investments
related to environmental protection.
• GreenInvestmentScheme(GIS)Part
4 – Construction and reconstruction
of electricity networks for connecting
renewable wind energy sources):
– An application round under GIS
Part 4 is planned for November.
The total budget of the program
amounts to Polish Zloty (PLN) 400
million.
– Eligible projects are those with
investment expenditures above
PLN8 million, involving the
construction or reconstruction of
electricity networks in order to
enable the connection of entities
producing renewable wind energy
to the National Electric Power
System (NEPS).
– Priority will be given to projects
implemented in areas with a
low110kVnetworkdensityand
with documented readiness for
implementation of the undertaking.
– Grants include PLN200 for each
kW of connected power from
renewable wind energy sources
but not more than 40 percent of
eligible investment costs.
As of 2013, companies in certain
provinces will have the opportunity to
apply for co-financing to support the
construction of installations designed
to produce energy from renewable
sources. The above incentives will be
applicable to smaller renewable energy
projects under the Regional Operational
Programs.
Operating subsidies
Green certificate system
Remuneration for renewable energy
produced: the average market price of
PLN201.36/MWh for the last year (2012)
plus the market value of green certificate
(certificate of origin) granted by the
Energy Regulatory Office.
Quota obligation
Rates (2013): 12 percent of all energy
produced (floors relate to all types
of renewable energy). The quota is
increasing in stages and will reach 13
percent in 2014 to 20 percent in 2021.
Additional information
Legal basis: The Act of Energy Law
enacted on 10 April 1997 and the
respective decrees from the Ministry of
Economy.
The Ministry of Economy announced
recently an act regarding renewable
energy sources which establishes under
Polish law the provisions of Directive
2009/28/WE. According to this act, the
level of support for renewable energy
will differ depending on the source
of renewable energy. The highest
support will be provided for photovoltaic
installations with the power productivity
exceeding 100 kW.
Administrative procedures: Business
activity in the area of production of
renewable energy is a licensed activity
and requires a permit granted by the
president of Energy Regulatory Office.
Such a permit can be sought by an entity
that meets requirements specified in
the Energy Law, especially the ability
to provide the financial, organizational
and technical resources required to
perform the licensed activity. As a rule,
permission is given for the fixed term but
not longer than 50 years.
Grid access: Priority access is granted
over nonrenewable electricity producers.
The costs of connecting to the electricity
grid are determined by the actual costs
incurred to construct the line. Those
costs may be partially refunded to the
investor, depending on the year and
production capacity.
Green certicates scheme: Electricity
producers may apply to the president
of Energy Regulatory Office for green
certificates (also known as certificates of
origin), if they have produced renewable
energy or if they are required to pay
substitute fees calculated in line with the
energy law. The green certificates are
similartosecurities;theyaretransferable
and tradable on the regulated market (for
example, the Polish Power Exchange) or
within the over-the-counter market.
Sale: Electricity distributors have a legal
obligation to acquire a certain amount
of renewable energy generated in
Poland. For the year of 2013, the above
percentage limit of renewable energy
will amount to 12 percent. Otherwise,
the electricity distributor is obliged to buy
the missing amount of renewable energy
(by means of green certificates) on the
market. The prices of renewable energy
have been determined based on average
prices of energy in the previous year.
(The amount for 2012 was PLN201.36
/MWh). The renewable electricity
producers have priority over other
producers with regards to the distribution
of produced energy.
41 | Taxes and incentives for renewable energy
Romania
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
Investment and other subsidies
Tax incentives
In Romania, the following tax incentives
may be applicable to energy produced
from the following renewable sources:
wind, solar, geothermal, hydro, biomass
and residues fermentation gas.
• Electricityfromrenewablesourcesis
excise duties exempt.
• Accelerateddepreciationfor
tax purposes can be used for
technological equipment, computers
and related peripheral equipment.
• Buildingsandlandusedwithin
hydroelectric, thermoelectric and
nuclear power plants, as well
as buildings and land relating to
transformation and connection posts,
are not subject to local taxes.
• Reinvesteddividendscanbedividend
tax exempt, provided the dividends
are used for the purpose of creating
new work places or developing the
activities of Romanian entities.
• Incentives(forexample,exemption
from payments to unemployment
funds or monthly grants) can also be
available to companies which provide
places of work for students, recent
graduates or disabled persons.
Operating subsidies
Green certificate system
The price of a green certificate has
been set between the Romanian
new leu (RON) equivalent of EUR29/
General Collateral (GC) and EUR59/GC.
Currently, the price of a green certificate
is equivalent with the maximum value of
EUR59/GC, since the demand of GC is
higher than the offer.
Quota obligation
In December 2012, the Romanian
Regulatory Authority in the Field of
Energy (ANRE) calculated the estimated
quota of GCs acquisition for 2013 for the
electricity suppliers as 0.21 GC/MWh
supplied to final consumers.
Additional information
Legal basis: Electricity Law 13/2007
and Law 220/2008 for approval of the
support scheme for electricity from
renewable sources (Law 220/2008) and
the secondary relating legislation issued
by ANRE.
Administrative procedures: The
activity of production of electricity from
renewable sources requires a license
granted by ANRE. Such a license can
be obtained by an entity that meets
certain requirements (relating to its
financial position, technical resources,
etc.) and provides a specific set of
documentation.
The license is granted for a fixed term,
but no longer than 25 years. In case of
production of electricity from renewable
sources, the maximum period during
which ANRE should issue the relating
license is reduced to 30 days (from 60
days).
Green certicate scheme: In order
to promote investments in renewable
electricity production capacities, a
Tradable Green Certificates (TGC or GC)
system has been in place in Romania
since 2004, coupled with a supplier
quota obligation system. Under this
framework, energy producers are
entitled to receive a set amount of GCs
according to the amount of electricity
generated by them from renewable
sources. The revenue from GC sales
represents additional revenue for
eligible renewable producers on top of
electricity sales on the market.
According to Law 220/2008, the
producers of electricity from renewable
sources benefit from a different number
of green certificates depending on the
fuel used. For example:
• between0.5and3GC/Mwfor
hydroelectric power, varying on the
capacity of the plant
• 2GC/MWhforwindpower,until31
December 2017
• 1GC/MWhforwindpower,starting
with 1 January 2018
• 6GC/MWhforsolarpower.
According to a report issued by
ANRE, the green certificates scheme
should be reduced in order to avoid
overcompensation. Therefore, the
authorities intend to grant 1.5 GC/MWh
for new wind plants, 1.3 GC/MWh for re-
used wind plants, 2.3 GC/MWh for new
hydroelectric power and 3 GC/MWh for
solar power.
The support scheme is granted for a
period of 3 to 15 years, depending on
the age of the plants and the installed
capacity. Eligible electricity producers
will be able to enter the scheme only if
the commissioning/refurbishment of
the power plant are performed before
31 December 2016.
Sale: The annual mandatory GCs
acquisition quota is established
based on the quantity of renewable
electricity produced and on the
final electricity consumption of the
previous year, without exceeding the
level corresponding to the mandatory
quota for the electricity produced from
renewable sources.
The quantity of electricity for which the
annual mandatory GCs acquisition quota
is established includes the electricity
purchased by electricity suppliers for
their own consumption or for the sale to
final consumer, the electricity used by
the electricity producers for their own
consumption (other than CPT), and for
the supply of end consumers directly
connected to the power plant.
Taxes and incentives for renewable energy | 42
Electricity suppliers and electricity
producers previously mentioned have
the obligation to acquire annually a
number of GCs which is equivalent
to the product between the annual
mandatory GCs acquisition quota and
the quantity of electricity detailed in the
paragraph above, supplied annually to
final consumers.
For 2013, the estimated quota of
acquisition of GCs for the electricity
suppliers is 0.21 GC/MWh delivered
to final consumers. Any supplier that
fails to fulfil this obligation must pay the
equivalent value of the GC at a premium
of EUR117.6 per each non-purchased
certificate.
The GCs are issued by the transmission
system operator and are valid for
16 months. The trading value of a GC
has been established by ANRE as
between the RON equivalent of EUR
29/GC and EUR59/GC. Currently, the
price of a green certificate is equivalent
with the maximum value of EUR59/GC,
because the demand of GC is higher
than the offer.
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43 | Taxes and incentives for renewable energy
South Africa
Support schemes
Investment and other subsidies
Carbon emissions incentives
Certied emissions reduction
exemption
Section 12K of the Income Tax Act
provides for a tax exemption on any
amount accrued in respect of the
disposal of any certified emission
reduction (CER) credit derived in
the furtherance of a qualifying clean
development mechanism.
To stimulate the uptake of Clean
Development Mechanism (CDM)
projects in South Africa, income from
primary certified emission reductions,
which was exempted from income tax
from 2009 to 2012, will be extended
to 31 December 2020, in line with the
adoption of the second commitment
period of the Kyoto Protocol.
TheVATActdoesnotprovidefor
exemptionfromVATonthedisposal
of a CER credit. It is arguable that the
disposal of CER credits should be
viewedasasupplyofservicesforVAT
purposes and that, on exportation of
CER credits, this service is zero-rated
forVATpurposes.
Energy efficiency incentives
Industrial policy projects additional
allowance
This is an incentive in relation
to industrial policy projects,
including greenfield and brownfield
manufacturing projects. One of the
qualifications for eligible projects is
the use of improved energy efficiency
and cleaner production technology.
Measurementandverication(M&V)
of savings will be required to verify that
savings are sustained over the incentive
benefit period of four years.
Under Section 12I of the Income Tax
Act (Industrial Policy Projects), projects
that have already received incentives or
grants under other types of schemes
will be excluded. Such projects need
to be ring-fenced and taken out of the
equation when calculating and reporting
savings for the tax claim.
Section 12I provides for an additional
allowance on assets (new or used),
applied to a project that qualifies
as an Industrial Policy Project (IPP)
defined in relation to assets used in the
manufacturing sector. The project must
be approved by the Minister of Trade
and Industry. Only projects larger than
South African rand (ZAR)200 million
qualify for this allowance.
The incentive in relation to a qualifying
project comprises:
• 75percentofthecostofanew
and unused manufacturing asset
used in an IPP within an Industrial
DevelopmentZone(IDZ);or
• 35percentofthecostofanewand
unused manufacturing asset that is
used in an IPP
• Ifthequalifyingprojectconstitutes
a Preferred Project (as defined), the
incentive comprises:
– 100 percent of the cost of a new
and unused manufacturing asset
usedinanIPPwithinanIDZ;or
– 55 percent of the cost of a new
and unused manufacturing asset
used in an IPP.
The incentive (i.e. tax deduction) is
limited to:
• ZAR900 million for greenfield
projects with preferred status
• ZAR550millionforgreeneld
projects with qualifying status
• ZAR550millionforbrowneld
projects with preferred status
• ZAR350millionforbrowneld
projects with qualifying status.
Energy efciency savings allowance
(legislation not yet in force)
Section 12L proposes as a deduction,
in determining the taxable income
of a taxpayer, an amount in respect
of energy efficiency savings by the
taxpayer with regard to that year of
assessment. The deduction will be
calculated at 45 cents per kilowatt hour
(or equivalent) of energy efficiency
savings. The energy efficiency savings
have to be measured and confirmed
by an institution, board or body as
prescribed by regulation. No deduction
is allowed if the taxpayer receives
a concurrent government benefit in
respect of energy efficiency savings.
This section, although promulgated in
the Income Tax Act, has not yet come
into effect. It will be effective on a
date as prescribed by the Minister of
Finance in the Government Gazette,
potentially during 2015 because the
National Treasury has indicated that
“some of the revenues generated
through the carbon tax will be recycled
to fund the energy efficiency savings tax
incentive.”
Production of renewable energy and
fuels allowance
Section 12B provides for an accelerated
capital allowance for machinery, plant
implements, utensil or articles, owned
by the taxpayer which was brought into
use for the first time by the taxpayer for
purpose of its trade.
This section applies where the assets
are used for purposes such as the
generation of electricity from wind,
sunlight, gravitational water forces or
biomass.
The allowance is calculated as 50
percent of the cost and construction
of the assets for the taxpayer in the
first year, 30 percent in the second
year, and 20 percent in the third year.
The allowance also applies to all
improvements (other than repairs) and
supporting structures that would form
part of the machinery, plant, implement,
utensil or article.
Research and development
allowance
Aside from the general 100 percent
deduction, this allowance (Section 11D)
provides for an additional 50 percent for
all expenditures incurred in respect of
eligible R&D activities.
The additional 50 percent uplift will
only apply to R&D approved by the
Department of Science and Technology.
R&D in respect to green and energy-
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Taxes and incentives for renewable energy | 44
saving industries has been identified as
a new area of focus.
Environmental incentives
Environmental treatment and
recycling or waste disposal asset
allowance
Section 37B provides for an allowance
with regard to the cost incurred
in acquiring a new and unused
environmental treatment and recycling
asset or environmental waste
disposal asset used in the context of
manufacturing.
The allowance in respect of an
environmental treatment and recycling
asset is 40 percent of the cost of the
asset in the first year and 20 percent
per annum for the next three years. The
cost of waste disposal assets can be
written off on a straight line basis over
20 years (five percent per year).
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Government grants/subsidies
Grants
PotentialGrant Description Rates/Basis Source
Manufacturing
Competitive
Enhancement
Programme
The MCEP is a cost-sharing incentive available to existing
manufacturers for expanding or upgrading facilities.
ThegrantisbasedonUnilever’sManufacturingValueAdded
(MVA)whichiscalculatedonsaleslesscostsofproduction.
The MCEP is further broken into several components, including
the Capital Investment and Green Technology and Resource
Improvement components.
The maximum grant
available is limited to 7-10
percentofMVA.
Within this limit a benefit
of 30 to 40 percent of
the expenditure may be
granted, capped at ZAR50
million.
Department
of Trade and
Industry (DTI)
MCEP The Capital Investment component is utilized to support upgrading
and expansion of equipment that will lead to the creation of new
jobs or the retention of existing jobs.
The main qualifying criteria is that jobs should be maintained
for two years and the company must be a level four B-BEEE
contributor or must have plans in place to achieve this score in
two years.
Applications need to be submitted at least 60 days prior to the
commencement of the commercial use of the assets.
Incentives
Potential
Grant Description Rates/Basis Source
Manufacturing
Investment
Programme
The MIP is a tax-free grant available to manufacturing entities
which is calculated based on the size of the project.
The grant is 15 percent
of qualifying costs of the
project.
Department
of Trade and
Industry (DTI)
MIP The MIP is available to existing manufacturers who plan to
increase their production facilities. The grant is payable over a
two year period.
A scoring system is in place to establish if the project will
qualify for this grant. Points are allocated based on the sector,
the B-BEEE score and the number of additional jobs created.
Applications need to be submitted at least three months prior
to planned commencement date of production.
45 | Taxes and incentives for renewable energy
South Korea
Support schemes
Investment and other subsidies
In 2004, the South Korean government
passed the Act on the Promotion of the
Development, Use And Diffusion of New
And Renewable Energy (the Act). With the
goal of becoming one of the five largest
producers of new and renewable energy,
the government has announced that a
total of South Korean won (KRW)40 trillion
(EUR25.8 billion, USD34.2 billion) will be
invested in renewable energy by 2015.
This investment includes KRW22.4
trillion invested by the nation’s 30 largest
industrial groups by 2013, KRW7 trillion of
government contribution, and KRW10.6
trillion from other private sectors. South
Korea has already seen substantial
financial investment in renewable energy
in recent years, including KRW2 trillion
(EUR1.3 billion, USD1.7 billion) from the
government in the last two years.
The revision of the Act on the Promotion
of the Development, Use And Diffusion
of New And Renewable Energy (the 4th)
will be issued by the first half year of 2013
and the target is expected to be revised
upward from existing target ‘renewable
energy supply rate 11 percent in 2030.
To reach this goal, the government is
implementing initiatives in four major
areas:
• strategicR&Dandcommercialization
• promotionofindustrializationand
market creation
• promotionofexportsofnewand
renewable energy products
• infrastructuredevelopment.
Operating subsidies
Feed-intariff
• Thefeed-intariffwasabrogatedatthe
end of 2011 due to introduction of a
renewable portfolio standard (RPS) in
2012. (The government maintains a
feed-in tariff only for existing recipients).
• Toaccommodatesmallrenewable
energy facilities that could not receive
support by RPS, the Seoul Solar Power
Plant Support Plan was announced
in May 2013. The plan supports
operations from the installation of
solar power plants to sales for small
entities under 50kW capacity in Seoul.
According to the plan, the small
entities can receive KRW50/kWh
(approximately 10 percent of installation
cost) for five years from 2013.
Premium
The R&D tax credit program is applied for
renewable energy technologies. Import
duties are reduced by 50 percent for all
components and/or equipment used in
renewable energy power plants.
The Financial Support Program for
Renewable Energy in South Korea is
comprised of two main categories: the
Electricity Fund and the Special Account
for Energy and Resource Projects.
The total budget in 2013 is KRW79.2
million, KRW64.2 million from the Special
Account, and KRW15 million from the
Electricity Fund. The government provides
subsidies up to 90 percent (in the case
of conglomerate, 50 percent) to the
approved applicants. Subsidies were set at
a variable interest rate (from 1.75 percent
to 2.25 percent in 2012), including a five-
year grace period followed by a 10-year
payment period.
Quota obligation
• In2012,theexistingfeed-intariffwas
replaced by an RPS that was approved
by the government assembly in March
2010.
• TheRPSrequires13state-runand
private power utilities with a capacity
in excess of 500 MW to generate
two percent of the energy production
from renewable sources by 2015. This
percentage will be increased in stages
to 10 percent by 2022.
• Intermsofthestandardpriceper
certificate, REC for solar power was
KRW184,200 averagely in 2012,
while REC for non-solar power was
determined to be KRW 32,331
regardless of its implementing method.
• ThetotalRPStargetfor2013was
conrmedasbeing9,210,381MWh;
increasing 41 percent from last year’s
target (6,420,279 MWh), while the RPS
target for solar power rose 270 percent
from 276,000 MWh to 723,000 MWh
in the same period.
Additional information
One Million Green Homes Project: As a
part of the 2009 budget, the government
appropriated KRW94.3 billion (USD72
million) for the One Million Green Homes
Project. The intent is to build one million
homes by 2020 that use one of the
following renewable energy technologies:
solar thermal, solar photovoltaic,
geothermal, biomass and wind energy.
Each year, the government will set a new
budget for the coming year.
The green homes being built are
environment-friendly and use new and
renewable energy resources. In addition,
green homes create no carbon emissions
and use less energy, water and natural
resources.
Other support programs: The
government will support 10 major green
projects that have impressive promotional
and installation effects.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Taxes and incentives for renewable energy | 46
Spain
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Support schemes
Tax incentives
The following includes a brief description
of certain tax incentives that have not been
specifically created for the renewable
energies sector. Careful tax planning is
therefore required to take advantage of
these tax incentives.
Reductionofincomefromcertain
intangible assets
The income derived from the license of
the right to use or exploit certain intangible
assets as defined in article 23 of CIT Law,
shall be included in the CIT taxable base
with a 50 percent reduction, and provided
certain requirements are met. This 50
percent reduction shall not be applicable
for the tax period following that when the
total income derived of the license of each
intangible asset that has benefited from
the reduction, calculated from the date on
which the license is issued exceeds six
times the cost of the intangible created.
CorporateIncomeTax(CIT)creditfor
investments in assets to protect the
environment
Article 39 of the Spanish CIT supports
investments in fixed assets aimed to
protect the environment, including facilities
designed to avoid atmospheric or acoustic
pollution from industrial installations, or
water pollution. An eight percent tax credit
is granted for any investment included in
programs, arrangements or agreements
entered with the environmental public
authorities of regional governments.
Tax credits may be carried forward to the
following tax year if they have not been
applied in a given fiscal year and have not
been used in that fiscal year because the tax
due was insufficient.
R&D Corporate Income Tax credits
R&Dtaxcredits:The tax credit base shall
consist of the amount of research and
development expenses and, if applicable,
investments in tangible fixed assets and
intangible assets, excluding real estate and
land.
Tax credit rates are set at 30 percent of the
expenses incurred in the tax period for this
purpose. In the event that the expenses
incurred in pursuing the R&D activities in
the tax period exceed the average of those
incurred in the two preceding years, the rate
established in the preceding paragraph shall
apply up to that average, and 50 percent
to the amount by which that average is
exceeded.
Technological innovation activities tax
credits: The tax credit base shall consist of
the amount of the expenses incurred in the
technological innovation activities. The tax
credit rate is 15 or 10 percent, depending on
the nature of the activities.
Capital duty exemption
As a result of the modifications introduced
by RD 13/2010, Spanish Transfer Tax Law
foresees an exemption of the Capital Duty
regarding:
• incorporationofcompanies
• sharecapitalincrease
• contributionsofshareholdersthatdonot
constitute a share capital increase
• transfertoSpainoftheofceofeffective
management of a company not
previously located in the EU.
Tax allowances on local taxes
For certain local taxes such as construction
and urban canon, tax allowances could be
determined at the local level. These tax
allowances would depend on each local
authority, and should be negotiated on a
case-by-case basis.
New taxes on energy
New taxes on electricity generation
Law 15/2012 entered into force on 1
January 2013. These taxes are not strictly
environmental taxes. Revenues created
by them will finance the Spanish deficit for
the cost of generation and distribution of
electricity. Taxes apply to:
• electricitygeneration
• nuclearrawandradioactivewaste
• nuclearrawandradioactivewaste
storage
• useofcontinentalwaterstogenerate
electricity (hydroelectricity generation).
Law 15/2012 has also established that the
electrical energy attributable to the use of
fuels in facilities that use any of the non-
consumable renewable energies as primary
energy shall not be subject to a premium-
based economic regulation. This affects
solar-thermal installations in particular.
Operating subsidies
Applicable for solar, wind, geothermal,
hydro, combined heat and power (CHP)
systems and biomaterials under 50 MW of
installed capacity.
Feed-intariff
Fixed remuneration is available for electricity
produced by power plants.
Premium
Spot price with a fixed premium (fixed
with an overall cap and floor, depending on
technology). The option of spot price plus
premium has been eliminated by Royal
Decree-Law 2/2013.
Other subsidies
General regulation of the legal regime of
electricity production from renewable
sources is contained in RD 661/2007. As
per operating subsidies for renewable
energy(exceptphotovoltaicorPV),
they are determined by RD 661/2007
governing renewable technologies. Solar
PVtechnologyincentivesfortheplants
entering in the system after September
2008 are specifically governed by RD
1578/2008 and refer only to feed-in tariffs.
Until January 2012, incentives for new
renewable plants were granted, provided
that projects were filed with the “registry
for pre-allocation,” subject to limitations on
the total capacity defined.
However, all incentives granted to new
renewable plants that are not yet included
in the registry of pre-allocation (for instance,
those wind power plants envisaged to
enter after 1 January 2013) are currently
suspended by the RD-L 1/2012. The registry
of pre-allocation has been cancelled as
well, leaving open the establishment of
new special economic regimes for certain
47 | Taxes and incentives for renewable energy
installations and the right to receive a
specific economic system under certain
assumptions.
Prior to this RD-L 1/2012, relevant
regulatory changes have been recently
introduced by RD 1614/2010, RD
1565/2010 and RD-Law 14/2010. Mainly
focusedonwind,solarPVandsolar
thermal energy production, these changes
concern existing power plants or those
under construction. Some of the legal
changes substantially modify the legal
regime (both economic and operational) of
these plants.
The following sections provide an outline
of some of these changes.
Wind and solar thermal technologies
(RD 1614/2010)
• Operationalhourlylimitsthatareentitled
for feed-in tariffs and premiums:
– For wind, a number of hours for all
the plants under this technology are
established(2,589hoursperyear),;
provided that an overall average of
production hours for total installed
wind power is reached (2,350 hours
per year).
– For solar, the hourly limits are
considered individually and depend
on technology, as follows:
Once exceeding such limitations, pool
prices should apply.
• AreviewofincentivesgrantedbyRD
661/2007 includes the following:
– For wind technology, in terms of
the feed-in tariff, the amount to be
applied will be the ones set under
regulation Order ITC/3519/2009.
Furthermore, RD 1614/2010 clarified that
the revisions of premiums, caps and floors
mentioned at article 44.3 of RD 661/2007
shall not affect those wind and SCP Plants
included in the pre-register.
As with solar thermal, during the 12 month
period after the start up of these plants, the
energy produced will have to be sold to the
market mandatorily under feed-in tariffs.
Furthermore, a time extension is granted
for the start up of solar thermal plants filed
in the Incentives’ Registry under phase 4
(until 31 December 2013).
Solar PV technology (RD 1565/2010 and
RD-Law 14/2010)
• Operationalhourlylimitationwith
the right to be granted feed-in tariffs,
depending on tracking technology and
individual considerations. In this regard,
a two-stage limitation is expected.
• AgeneralhourlylimitationforallPV
plants is approved with the following
conditions, with Spain divided into five
irradiation areas:
Solar thermal Hour
technology limitation
per year
Parabolic cylinder
without storage capacity
2,855
Parabolic cylinder with
storage capacity of
9 hours (h)
4,000
Parabolic cylinder with
storage capacity of 7 h
3,950
Parabolic cylinder with
storage capacity of 4 h
3,450
Saturated steam tower 2,750
Salt tower with 15 h
storage capacity
6,450
Fresnel 2,450
Stirling 2,350
Hourly limitation per year
Area Ar
ea Area Area Area
I II III IV V
Technology
Fixed
1.232 1.362 1.492 1.632 1.753
support
Single
axis 1.602 1.770 1.940 2.122 2.279
tracker
Dual
axis 1.664 1.838 2.015 2.204 2.367
tracker
Source: KPMG International, Taxes and Incentives for
Renewable Energy, 2011
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Taxes and incentives for renewable energy | 48
• ForthosePVplantsunderRD661/2007
economic regime, a special and
extraordinary limitation has been
approved until 31 December 2013:
• Ascompensationforthehourly
limitation set out above, feed-in tariffs
are extended from 25 to 30 years.
New relevant technical obligations are
establishedforPVplantstopermita
global technical management of the
grid.
Decrease of the feed-in tariffs established
under RD 1578/2008 with the Incentives
Registry (RD 1565/2010):
• 5percentdecreasefortypeI1
installation
• 25percentdecreasefortypeI2
installations
• 45percentdecreasefortypeII
installations.
Cancellation of the registry of pre-
allocation of new special regime
installations(RD-Law1/2012)
• Duetothedecitproblemgenerated
by the Spanish electrical system,
and based on a possible excess of
renewable capacity considering the
objectives of 2020, the government
has decided to temporarily suspend
the registration of new special-
regime plants along with the special
regime of incentives for these plants.
As a result, developers who wish to
construct new plants in this situation
will not receive incentives but only
the market price.
• Thisnewpolicychangewillapplyonly
for those special-regime facilities that
would not have been entered in the
registry of pre-allocation according to
RD-Law 6/2009 and RD 1578/2008
forPVtechnologies.Thischangewas
made with the intention of avoiding
the retroactive character of the
measure.
• Feed-intariffs,premiumsandlimits
laid down are cancelled for new
plants, as well as the supplement for
efficiency and reactive energy.
• Additionally,RoyalDecree-Law
29/2012 of 28 December 2012
established that the economic
regime of incentives applicable
to renewable producers of the
special regime will be cancelled
if an installation registered in the
pre-allocation registry has not
been completed by the deadline
for definitive registration in the
registry of special regime production
installations and has started to sell
energy.
MeasuresintroducedbyRoyal
Decree-Law2/2013of1February2013
This regulation, which seeks to reduce the
costs of the Spanish electrical system, has
established the following measures:
• ReplacementoftheConsumerPrice
Index (CPI) with the CPI at constant
tax rates (excluding unprocessed
food and energy products). This
measure is designed to update the
remuneration of those technologies
referenced in this index.
• Cancellationofthepremium
established for renewable
installations that sell their energy
to the market. In this sense, RD
661/2007 has been modified and
now establishes that the value of the
premium applicable to all groups and
sub-groups shall be EUR0.0/kWh.
• Renewablegeneratorsdonothave
the choice to opt between market
price plus premium and feed-in
tariffs. By contrast, all renewable
generators have to be subject to
feed-in tariffs unless they choose to
sell at market price without premium.
Additional information
Considerations regarding operating
subsidies for renewables:
Duration: Subsidies are granted from
15 to 25 years. Depending on the
technology, subsidies are substantially
reduced after this period.
Update: Subsidies are updated annually
according to the CPI at constant tax rates
excluding unprocessed food and energy
products.
Payment: Part of the total subsidies
amount is liquidated by the Spanish
National Energy Commission (Comisión
Nacional de Energía or CNE) and paid by
the energy distributors. The remainder
is liquidated and paid by the market and
system operator.
Administrative procedures: Main
permits and authorizations include
electric sector authorizations, municipal
permits and licenses, and environmental
procedures. At an environmental level, it
should be emphasized that public tenders
arecarriedoutforonshorewindandPV
projects to determine locations that are
environmentally friendly. As per offshore
wind, a national map has been approved
with possible project locations.
Grid access: Access priority is given over
other non renewable electricity producers.
Full access is not guaranteed but depends
on the technical management of the
grid and demand. The costs concerning
the access to the grid will be paid by the
energy producers. Access to the grid will
only be denied by grid operators in the case
of a lack of capacity according to security,
quality supply and regularity criteria.
Technology Hourly limitation
per year
Fixed support 1.250
Single axis tracker 1.644
Dual axis tracker 1.707
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
49 | Taxes and incentives for renewable energy
Sweden
Support schemes
Depreciationofwindmills
Swedish tax law allows tax payers to
depreciate windmills for (corporate)
income tax purposes at a rate that
is much faster than the actual rate
of economic loss. The maximum
depreciation allowance is 30 percent
of the aggregate book value at the
beginning of the tax year, plus the
building or acquisition costs that have
been made during the year.
If a straight-line depreciation of
20 percent per annum results in a lower
aggregate book value in any year, the
annual depreciation allowance may
be increased correspondingly. The
depreciation allowance is calculated on
a pool basis, with the book value of all
the taxpayer’s assets taken into account
in order to calculate the maximum
depreciation allowance.
Operating subsidies
For each MWh produced by renewable
sources (solar, geothermal, wind, wave,
bio fuels or hydro) the producer receives
one certificate. (Some limitations
exist for hydro power generation). A
distributor is obliged to buy certificates
up to a certain percentage of the
power distributed. In this way a market
is established for selling and buying
certificates.
To support the transition to more
sustainable energy sources for heating
and transportation, no taxes are levied
on renewable fuels while energy taxes,
CO
2
taxes and sulphur taxes are levied
on fossil fuels.
There is also a fee-based system for
the reduction of greenhouse gas (GHG)
emissions.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Taxes and incentives for renewable energy | 50
Tu rke y
Support schemes
Investments and other subsidies
General Investment Incentive Regime
has changed in June 2012. This new
incentive regime is applicable to ENR
investments, mainly by providing the
following:
• VATexemptiononpurchase(or
import) of investment equipment
• customsdutyexemptiononimportof
investment equipment
• exemptionfromotherfundsand
surcharges.
Other subsidies
The new Electricity Market Law 6446
became effective as of 30 March 2013.
The incentives provided under this law
apply to investors holding a generation
license and beginning operations before
31 December 2015:
• A50percentdiscountisappliedto
the transmission system utilization
fee for five years following the start of
operations.
• Documentsandtransactionsrelated
to the power plants and concluded
throughout the investment period are
exempted from stamp tax and duties.
Operating subsidies
Feed-intariff
The tariff and the government purchase
guarantee are applied for 10 years
following the start of operations
of a generation power plant until
31 December 2015.
Resources:
• Hydro:USDcent(ct)7.3kWh
• Wind:ct7.3/kWh
• Geothermal:ct10.5/kWh
• Solar:ct13.3/kWh
• Biomass(includinglandll):
ct13.3/kWh
Discountonfees
The new Electricity Market Law 6446
has become effective as of 30 March
2013. Under this law, an 85 percent
discount is applied to the lease,
easement and utilization right of energy
transfer lines for 10 years in both
investment and operating periods.
Additional information
• Ifthemechanicaland
electromechanical equipment used
in renewable energy facilities that
have started operation before 31
December 2015 are manufactured
in Turkey, an additional incentive
of between ct0.4 and 2.4/kWh for
five years will be provided to such
facilities, under certain conditions.
• Renewableenergysourcesbased
electricity generation power
plants with an installed capacity of
maximum 1 MW and other similar
investments are allowed to operate
without a generation license.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
51 | Taxes and incentives for renewable energy
United Kingdom
Support schemes
Investments and other subsidies
Exemptions are in effect from the
Climate Change Levy and Emissions
Trading Scheme.
Operating subsidies
Renewableobligationscheme
Long-term banded quota mechanism
designed to support renewable
electricity generation.
Feed-intariff(smallscalegeneration)
Tariff support payments for small-scale
electricity generation from a variety of
technologies.
Renewableheatincentive
Long term tariff support payments for
renewable heat generation.
Additional information
Electricity market reform: In
November 2012, the UK government
introduced the Energy Bill, expected to
become law in summer 2013, outlining
major reforms to the UK market. Key
features include the introduction of a
two way, feed-in tariff with Contract for
Difference (“CfD”) for each low-carbon
generation technology. This provision
is scheduled to replace the Renewable
Obligation Scheme by 2017. The CfD is
expected to last for at least 15 years and
take effect from 2014/15 onwards.
Renewable Obligation (RO) scheme:
This requires electricity suppliers
to source a specific percentage of
electricity from renewable sources.
Renewable generators receive
Renewable Obligation Certificates
(ROCs) for each MWh of electricity
generated, and these ROCs can be
traded independently of the electricity
generated.
There is a banded ROC mechanism
whereby different renewable electricity
technologies receive different levels of
support according to their technological
maturity and levelized costs (see table
below). A supplier who does not obtain
sufficient ROCs over a year has to make
buy out payments at British pound
(GBP) 42.02/MWh (2013 to 2014 rate).
The government has confirmed that
applications for the RO regime can be
made until 2017, thereby extending
the scheme until 2037. Renewable
generators may not receive a CfD and
also participate in the RO regime.
ROCbandingregime
Band Technologies Current Banding(2013-2017)
Established 1 Landfill gas 0.25 0.00 - 0.20
Established 2 Sewage gas
Co-firing of regular biomass (std)
Co-firing of regular biomass (enhanced)
0.50 0.50
0.30 (2013-15)/0.50 (2015-16)
Mid-range (50-85%): 0.60
High-range (85-100%): 0.70 (2013-14)/0.90 (2014-17)
Reference Onshore wind 1.0 0 0.90
Hydro-electric
Co-firing of energy crops
EfW with CHP
0.70
1.50 - closed to new accreditation from 1 April 2015
1.0 0
Geopressure
Co-firing of biomass with CHP
Standard gasification and Pyrolysis
1.0 0
1.50 (2013-15) closed to new accreditation from 1 April 2015
2.00 (2013-15)/1.90 (2015-16)/1.80 (2016-17)
Post-
demonstration
Offshore wind (2014-15)
Biomass conversion
1.50 2.00 (2013-15)/1.90 (2015-16)/1.80 (2016-17)
1.0 0
Biomass conversion with CHP
Dedicated regular biomass
Co-firing of energy crops (with CHP)
1.50 (2013-15) closed to new accreditation from 1 April 2015
1.50 (2013-16)/1.40 (2016-17)
2.00 (2013-15) closed to new accreditation from 1 April 2015
Engineering
technologies
Offshore wind (2013-14)
Wave and tidal stream
Tidal barrage (<1GW) and lagoon (<1GW)
Advanced conversion technologies
Dedicated energy crops
Dedicated biomass with CHP
Solar photovoltaic
Geothermal
Micro-generation
2.00 2.00 (2013-15)/1.90 (2015-16)/1.80 (2016-17)
2.00 (2013-15)/1.90 (2015-16)/1.80 (2016-17)
2.00 (2013-15)/1.90 (2015-16)/1.80 (2016-17)
2.00 (2013-15)/1.90 (2015-16)/1.80 (2016-17)
2.00 (2013-15)/1.90 (2015-16)/1.80 (2016-17)
2.00 (2013-15)/1.90 (2015-16)/1.80 (2016-17)
Subject to further consultation
2.00 (2013-15)/1.90 (2015-16)/1.80 (2016-17)
2.00 (2013-15)/1.90 (2015-16)/1.80 (2016-17)
Source: Renewables Obligation for the period 2013-17-DECC response to public consultation, July 2012
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Taxes and incentives for renewable energy | 52
Climate Change Levy (CCL),
renewables exemption:
The CCL is a specific energy tax on
non-domestic users of electricity in
the United Kingdom. Most electricity
generated from renewables is exempt
from the CCL. Renewable Levy
Exemption Certificates (LECs) are
issued to renewables generators for
each MWh of electricity supplied. LECs
transfer along with the electricity and
can be used by electricity suppliers to
claim the CCL exemption.
The Carbon Price Floor, introduced from
1 April 2013, applies a levy on certain
types of fossil fuels used to generate
electricity and so provides a disincentive
for fossil fuel generators which
renewable electricity generators will not
be subject to:
• gasatGBP0.00091/kWh
(GBP0.00175 from 1 April 2014)
• LPGatGBP0.01460/kg(GBP0.02822
from 1 April 2014)
• CoalatGBP0.44264/GJ(GBP0.85489
from 1 April 2014)
Feed-in tariffs (small scale
generation)
Feed-in tariffs are available for small-
scale, low-carbon electricity generated
by private/business users (maximum
capacity 5 MW) providing payment
of up to British pence (p) 21.65/kWh
generated (depending on the type and
size of the system used to generate
renewable energy) plus a guaranteed
p4.64/kWh sold to the UK electricity
grid. Typically the tariffs last for 20 years.
Renewable Heat Incentive (RHI)
A two phase long-term tariff support for
renewable heat generation:
• Phase1,whichbeganinDecember
2011, provides tariff support to help
meet the cost of installing renewable
heat technologies for organizations in
the non domestic sector. Payments
of up to p8.9/kWh may be made
depending on the technology used.
Phase 1 also introduced the RHI
Premium payment, which is a GBP15
million fund for households that
install renewable heating. In return
for the payments, participants will
have to provide feedback on how the
equipment performs in practice.
• Phase2,extendingtheschemeto
tariffs for domestic properties as
part of the “Green Deal,” whereby
householders may make energy-
efficiency improvements to their
houses and pay back the cost
of these over time through their
electricity bill. This incentive is
expected to be introduced in spring
2014.
EU Emissions Trading Scheme
exemption
Renewable generators are exempted
from the requirement to purchase
carbon allowances in order to generate
electricity, as stipulated by the EU
Emissions Trading Scheme.
Other direct tax allowances/
incentives potentially relevant to
renewables generators
• From1April2012capitalallowances
of 18 percent reducing balance for
capital expenditures on plant and
machinery (reduced to eight percent
if the asset’s useful expected
economic life exceeds 25 years).
• Enhancedcapitalallowances
(a 100 percent First Year Allowance
for expenditure incurred on or before
31 March 2013 on specified energy-
saving plant and machinery). A
19 percent cash tax credit is available
for loss-making companies up to
GBP250,000 or the company’s PAYE
and NIC liabilities, whichever is less.
• Contaminatedlandremediation
tax relief on qualifying expenditure,
attracting an additional 50 percent tax
deduction (or a 16 percent cash tax
credit for loss-making businesses).
• R&Dtaxreliefofanenhancedtax
deduction of 130 percent for large
companies and 225 percent for
SMEs from 1 April 2012 for revenue
expenditure on qualifying projects
seeking to achieve an advance
through the resolution of scientific
or technological uncertainty. From
1 April 2013, large companies may
instead claim an above-the-line tax
credit which gives a taxable payment
of 10 percent (7.7 percent after tax) on
qualifying revenue expenditure.
• 100percentallowanceoncapital
expenditure on R&D in the year of
expenditure.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
53 | Taxes and incentives for renewable energy
United States
Support schemes
Investments and other subsidies
Production Tax Credit (PTC)
Applicable for wind, geothermal,
landfill gas, trash combustion, open-
loop biomass, closed-loop biomass,
hydropower and wave tide.
• ThePTCprovidesataxcreditfor
the production of electricity from
renewable sources and the sale of
that electricity to an unrelated party.
• Creditamountis:
– USD cents (ct) 2.3/kWh for
wind, closed-loop biomass and
geothermal
– ct1.1/kWh for other renewable
energy resources.
• Availableforfacilitiesthatbegin
construction prior to 1 January 2014.
• Availablefora10-yearperiod
beginning the year the facility is
placed in service.
• Therearetwomethodsthata
taxpayer may use to establish that
construction has begun:
– A taxpayer may establish the
beginning of construction when
“physical work of a significant
nature” is started.
– A taxpayer may establish the
beginning of construction by
meeting a safe harbor rule.
• Ingeneral:
– Work performed by the taxpayer
and work performed for the
taxpayer by other persons
under a binding written contract
that is entered into prior to the
manufacture, construction, or
production of the property for use
by the taxpayer in the taxpayer’s
trade or business (or for the
taxpayer’s production of income) is
taken into account in determining
whether physical work of a
significant nature has begun.
– Whether a taxpayer has begun
construction of a facility before
1 January 2014, will depend on the
relevant facts and circumstances.
– The IRS will closely scrutinize
a facility, and may determine
that construction has not begun
on a facility before 1 January
2014, if a taxpayer does not
maintain a continuous program of
construction.
• Thesafeharborruleprovidesthat
construction of a facility will be
considered as having begun before 1
January 2014, if:
– the taxpayer pays or incurs –
within the meaning of Reg. section
1.461-1(a)(1) and (2) – 5 percent or
more of the total cost of the facility
before1January2014;and
– subsequently, the taxpayer makes
continuous efforts to advance
towards completion of the facility
(as determined under Notice 2013-
29).
Investment Tax Credit (ITC) in lieu of
the PTC
Applicable for facilities that are eligible
for the PTC and that begin construction
before 2014.
• TheITCisavailableinlieuofthePTC.
• TheITCprovidesacreditfor
qualifying energy property.
• Thecreditamountis30percentof
the eligible cost basis of the property.
• Eligiblepropertyistangiblepersonal
property or other property that is
integral to a PTC-eligible facility.
• Thedenitionof“beginconstruction”
is the same for the ITC in lieu of the
PTC as for the PTC.
Investment Tax Credit (ITC)
Applicable for solar, geothermal,
qualified fuel cell or micro turbine
property, combined heat and power
systems, small wind and geothermal
heat pumps.
• TheITCprovidesacreditfor
qualifying energy property.
• TheITCforanytaxableyearisthe
energy percentage of the basis
of each energy property placed in
service during the taxable year.
• Creditamountis:
– 30 percent of eligible costs for fuel
cell, solar, and small wind property
– 10 percent of eligible costs
for combined heat and power,
microturbine property and
geothermal heat pumps.
• TheITCisgenerallyavailablefor
eligible property placed in service on
or before 13 December 2016.
Grant in lieu of PTC and ITC
Applicable for tangible personal property
or other property that is an integral part
of a qualified facility (as defined by the
PTC and ITC rules).
• TheAmericanRecoveryand
Reinvestment Act of 2009 (ARRA)
enacted a grant program which
provides a cash grant in lieu of the
PTC or ITC.
• ARRApermitsPTCorITCprojectsto
elect a grant of up to 30 percent of
costs of construction of PTC or ITC
energy property in lieu of tax credits.
• Projectsmustbeginconstruction
before 2012 and submit a grant
application no later than
30 September 2012.
• Projectsmustbeplacedinservice:
– before 2014 for PTC-eligible
facilities (before 2013 for wind)
– before 2017 for other ITC eligible
projects.
© 2013 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.
Taxes and incentives for renewable energy | 54
Operating subsidies
Quota obligation
Renewable Portfolio Standards (RPS)
This standard generally places an
obligation on electric supply companies
to produce a specified fraction of their
electricity from renewable energy sources
and enumerates mechanisms that are
permitted to achieve compliance, such
as renewable energy credits (RECs).
Currently no federal RPS legislation has
been enacted. A total of 29 states and
the District of Columbia have an RPS.
The states include Arizona, California,
Colorado, Connecticut, Delaware, Hawaii,
Illinois, Indiana, Kansas, Maine, Maryland,
Massachusetts, Michigan, Minnesota,
Missouri, Montana, Nevada, New
Hampshire, New Jersey, New Mexico,
New York, North Carolina, Ohio, Oregon,
Pennsylvania, Rhode Island, Texas,
Washington and Wisconsin.
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55 | Taxes and incentives for renewable energy
Uruguay
Support schemes
Investments and other subsidies
General Investment Regime
Investment Law 16.906 declares the
national interest of the promotion and
protection of domestic and foreign
investment and, through Decree 2/012,
establishes the following benefits
for the investments carried out in the
country:
• CorporateIncomeTax(CIT)
exemption equivalent to a percentage
of the investment in fixed assets
(machinery, equipment and civil
works).
43
The referred percentage
varies between 20 percent and
100 percent of eligible investment
and it is determined by the score the
project receives for its impact
in terms of:
– employment
– decentralization
– exports
– clean production
– industrial indicator.
• CapitalTaxexemptionforthexed
assets included in the investment:
– civil works: Eight years for civil
works in Montevideo and 10 years
in the rest of the national territory
– machinery and equipment for the
useful life
• FiscalcreditforVATsincludedincivil
works.
• Exemptionfromalltaxesandduties
levied on the import of machinery and
equipment that is not competitive
with national industry.
Particular Investment Regime
for renewable energy
Within the frame of Law 16.906, Decree
354/009 establishes particular benefits
for the generation of electricity from
non-traditional renewable sources
(defined as the native renewable
sources such as wind, solar thermal,
photovoltaic(PV),geothermal,tidal
and wave energy, as well as the energy
produced from the use of different
types of biomass).
The main benefit consists of CIT
exemptions equivalent to:
• 90percentofnetscalincome
generated by the promoted activity
for all fiscal years up to 31 December
2 01 7.
• 60percentofnetscalincome
generated by the promoted activity
for all fiscal years from 1 January
2018 to 31 December 2020.
• 40percentofnetscalincome
generated by the promoted activity
for all fiscal years from 1 January
2021 to 31 December 2023.
Other benefits:
• Thelawdeclaresofnationalinterest
the national production of machines
and equipment necessary for the
production of these renewable
energies and also applies to this
activity the CIT exemption described
in the Particular Investment Regime
for renewable energy. As a condition
for the application of this exemption,
at least 35 percent of their cost must
correspond to Uruguayan inputs.
• Purchaseofthewindturbineandits
accessoriesareexemptfromVAT.
Promotionofsolarthermalenergy
In 2009, Law 18.585 declared of national
interest the investigation, fabrication,
implementation and development of
solar thermal energy. The law, along
with Decree 451/011, established
theexemptionofVAT,InternalExcise
Tax (IMESI), duties and custom taxes
applicable to:
• Nationalandimported(non
competitive with the national
industry) goods and services
necessary to fabricate solar collectors
in Uruguay.
• Saleofsolarcollectorsfabricatedin
Uruguay.
• Importofsolarcollectorsnon
competitive with the national
industry.
In 2012, the Government launched a
Solar Program focused on developing
solar thermal energy for residential
users. The new program provides
loans, financial discounts and payment
facilities for those who install solar
thermal technology in their houses.
Quota obligation
Law 18.585 also introduced the
obligation of incorporating solar thermal
technology in sport clubs, hospitals,
hotels and heated swimming-pool,
under certain circumstances. According
to this law, at least 50 percent of the
energy required to heat the water
should come from solar thermal energy.
If this requirement is not fulfilled, the
permit for the construction works is
denied.
New public buildings (that is, state
owned) are also obliged to incorporate
this source of energy.
43
Corporate Income Tax regular rate is 25 percent of the net Uruguay-sourced income of the company.
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Taxes and incentives for renewable energy | 56
As from June 2012, the Ministry of
Industry is entitled to request to all
new industrial and agro-industrial
developments to perform a technical
study on the feasibility of incorporating
solar thermal technology to the project.
Additional information
Uruguay is recognized as a country
with excellent conditions for the
development of renewable energy,
attracting the attention of national and
international investors. The government
– with the support of the opposition
parties – has set forth the goal of
becoming a model country in this area.
The authorities intend that, by the year
2015, at least 50 percent of the primary
energy matrix of the country will come
from renewable sources.
Wind
Although the focus is placed on all types
of renewable energy, the most popular
these days is wind power. The initial goal
of reaching 300 MW of wind generation
by 2015 is expected to be fully achieved,
as well as the 2016 goal of 1200 MW,
assuming all the awarded wind farm
projects are implemented. Investment
in this area has reached USD2 billion.
Biomass
In 2010 the government set the goal of
incorporating 200 MW from biomass
sources to the primary energy matrix
by 2015. Accordingly, the Uruguayan
energy utility (Usinas y Trasmisiones
Eléctricas or UTE) promoted one tender
during 2011, in which the total amount
offered by the private companies has
already exceeded the 350 MW.
Uruguay has several natural resources
that can be used as primary elements
for the generation of biomass energy:
• extensiveforestsprovidingwoodfor
energy generation
• industrialforestryresidues(sawmill
residues, black liquor, etc)
• ricehusks
• residuesfromsugarcane,sweet
sorghum and other cereals
• excellentconditionsforelephant
grass
• aguaranteedsupplyofbiomassfrom
livestock and agriculture.
SolarPhotovoltaic(PV)
At the moment, the only ongoing
projectisasolarPVfarmof480
kilowatts-peak (kWp) and 10.000 m2
ofPVmodules,locatedinthenorthof
the country. The farm is owned by UTE
and was financed by the International
Cooperation Agency of Japan under the
scope of the “Cool Earth Program” of
the Japanese government.
In May 2013 the Government launched
a tender call for the purchase of solar
PVenergy.Thetendercontemplates
projects of three different ranges: i) 500
kW to 1 MW, ii) 1 MW to 5 MW and iii) 5
MW to 50 MW.
For ranges i) and ii), the bidders have to
offer a price and the total amount to be
awarded cannot exceed 6 MW. On the
other hand, for range iii), bidders will
have to adhere to a pre-established price
of USD91.5/MWh, and the total amount
to be awarded cannot exceed 200 MW.
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57 | Taxes and incentives for renewable energy
44
Solar water collector (heating) rankings are for 2011, and are based on capacit y of glazed water collectors only (excluding unglazed systems for swimming pool heating
and air collectors). Including all water and air collectors, the 2011 ranking for total capacity is China, United States, Germany, Turkey, and Brazil.
45
Per capita renewable power capacity ranking considers only those countries that place among the top 12 for total renewable power capacity, not including hydro.
46
Insomecountries,ground-sourceheatpumpsmakeupasignicantshareofgeothermaldirect-usecapacity;theshareofheatuseislowerthantheshareofcapacityfor
heat pumps because they have a relatively low capacity factor. Rankings are based on a mix of 2010 data and more recent statistics for some countries.
Notes:Mostrankingsarebasedonabsoluteamountsofinvestment,powergenerationcapacity,orbiofuelsproduction;ifdoneonapercapitabasis,therankingswould
bequitedifferentformanycategories(asseenwithpercapitarankingsforrenewablepower,solarPV,andsolarwatercollectorcapacity).Countryrankingsforhydropower
would be different if power generation (TWh) were considered rather than power capacity (GW) because some countries rely on hydropower for baseload supply whereas
others use it more to follow the electric load and match peaks in demand.
Top five countries 2012
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TOPFIVECOUNTRIES 1 2 3 4 5
Annual investment/additions/production in 2012
New capacity investment China United States Germany Japan Italy
Hydropower capacity China Turkey Brazil/Vietnam Russia Canada
SolarPVcapacity Germany Italy China United States Japan
Wind power capacity United States China Germany India United Kingdom
Solar water collector (heating) capacity
44
China Turkey Germany India Brazil
Biodiesel production United States Argentina Germany/Brazil France Indonesia
Ethanol production United States Brazil China Canada France
Total capacity as of end-2012
Renewable power (including hydro) China United States Brazil Canada Germany
Renewable power (not including hydro) China Unites States Germany Spain Italy
Renewable power per capita
Germany Sweden Spain Italy Canada
(not including hydro)
45
Bio-power United States Brazil China Germany Sweden
Geothermal power United States Phillippines Indonesia Mexico Italy
Hydropower China Brazil United states Canada Russia
Concentrating solar thermal power Spain United States Algeria Egypt/Morocco Australia
(CSP)
SolarPV Germany Italy United States China Japan
SolarPVpercapita Germany Italy Belgium Czech Republic Greece
Wind power China United States Germany Spain India
Solar water collector (heating)
44
China Germany Turkey Brazil India
Solar water collector (heating) per Cyprus Israel Austria Barbados Greece
capita
44
Geothermal heat capacity United States China Sweden Germany Japan
Geothermal direct heat use
46
China United States Sweden Turkey Japan/Iceland
Taxes and incentives for renewable energy | 58Taxes and incentives for renewable energy | 58
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59 | Taxes and incentives for renewable energy
AppendixA:REN212012RenewablesGlobalStatusReport
Table1.Renewableenergysupportpolicies
Australia
Renewable energy
targets
Feed-in tariff/
premium payment
Electric utility
quota obligation/
RPS
Net metering
Biofuels obligation/
mandate
Heat obligation/
mandate
Tradable REC
Capital subsidy,
grant, or rebate
Investment or
production tax
credits
Reductions in
sales, energy, CO
2
,
VAT or other taxes
Energy production
payment
Public investment,
loans, or grants
Public competitive
bidding/tendering
Austria
Barbados
Belgium
Canada
Croatia
Cyprus
Czech Republic
Denmark
Estonia
Finland
France
Germany
Greece
Hungary
Ireland
Israel
Italy
Japan
Luxembourg
Malta
Netherlands
New Zealand
Norway
Oman
Poland
Portugal
Singapore
Slovakia
Slovenia
South Korea
Spain
47
Sweden
Switzerland
Trinidad and Tobago
United Arab Emirates
United Kingdom
United States
HIGH-INCOME COUNTRIES
REGULATORY POLICIES AND TARGETS FISCAL INCENTIVES
PUBLIC
FINANCING
Some states/
provinces within
these countries have
state/provincial-level
policies but there is no
national-level policy.
47
In Spain, the feed-in tariff (FIT) and net metering programmes have been temporarily suspended by Royal Decree for new renewable energy projects; this
does not affect projects that have already secured FIT funding. The Value Added Tax (VAT) reduction is for the period 2010–12 as part of a stimulus package.
Note: Countries are organised according to GNI per capita levels as follows: “high” is USD 12,476 or more, “upper-middle” is USD 4,036 to USD 12,475,
“lower-middle” is USD 1,026 to USD 4,035, and “low” is USD 1,025 or less. Per capita income levels and group classifications from World Bank, 2012. Only
enacted policies are included in the table; however, for some policies shown, implementing regulations may not yet be developed or effective, leading to lack of
implementation or impacts. Policies known to be discontinued have been omitted. Many feed-in policies are limited in scope of technology.
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Taxes and incentives for renewable energy | 60
Table1.Renewableenergysupportpolicies(continued)
Algeria
Renewable energy
targets
Feed-in tariff/
premium payment
Electric utility
quota obligation/
RPS
Net metering
Biofuels obligation/
mandate
Heat obligation/
mandate
Tradable REC
Capital subsidy,
grant, or rebate
Investment or
production tax
credits
Reductions in
sales, energy, CO
2
,
VAT or other taxes
Energy production
payment
Public investment,
loans, or grants
Public competitive
bidding/tendering
Argentina
Belarus
Bosnia and Herzegovina
Botswana
Brazil
Bulgaria
Chile
China
Colombia
Costa Rica
Dominican Republic
Ecuador
Grenada
Iran
Jamaica
Jordan
Kazakhstan
Latvia
Lebanon
Libya
Lithuania
Macedonia
Malaysia
Mauritius
Mexico
Montenegro
Palau
Panama
Peru
Romania
Russia
Serbia
South Africa
St. Lucia
Thailand
Tunisia
Turkey
REGULATORY POLICIES AND TARGETS FISCAL INCENTIVES
PUBLIC
FINANCING
Uruguay
Some states/
provinces within
these countries have
state/provincial-level
policies but there is no
national-level policy.
UPPER-MIDDLE INCOME COUNTRIES
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61 | Taxes and incentives for renewable energy
Table1.Renewableenergysupportpolicies(continued)
Armenia
Renewable energy
targets
Feed-in tariff/
premium payment
Electric utility
quota obligation/
RPS
Net metering
Biofuels obligation/
mandate
Heat obligation/
mandate
Tradable REC
Capital subsidy,
grant, or rebate
Investment or
production tax
credits
Reductions in
sales, energy, CO
2
,
VAT or other taxes
Energy production
payment
Public investment,
loans, or grants
Public competitive
bidding/tendering
Cameroon
Cape Verde
Côte d’Ivorie
Egypt
El Salvador
Fiji
Ghana
Guatemala
Guyana
Honduras
India
Indonesia
Lesotho
Marshall Islands
Micronesia,
The Federated States of
Moldova
Mongolia
Morocco
Nicaragua
Nigeria
Pakistan
Palestinian Territories
48
Paraguay
Philippines
Senegal
Sri Lanka
Sudan
Syria
Ukraine
Vietnam
LOWER-MIDDLE INCOME COUNTRIES
REGULATORY POLICIES AND TARGETS FISCAL INCENTIVES
PUBLIC
FINANCING
Some states/
provinces within
these countries have
state/provincial-level
policies but there is no
national-level policy.
48
The area of the Palestinian Territories is included in the World Bank country classification as “West Bank and Gaza.” They have been placed in the table using
the 2009 “Occupied Palestinian Territory” GNI per capita provided by the United Nations (USD 1,483).
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Taxes and incentives for renewable energy | 62
Bangladesh
Renewable energy
targets
Feed-in tariff/
premium payment
Electric utility
quota obligation/
RPS
Net metering
Biofuels obligation/
mandate
Heat obligation/
mandate
Tradable REC
Capital subsidy,
grant, or rebate
Investment or
production tax
credits
Reductions in
sales, energy, CO
2
,
VAT or other taxes
Energy production
payment
Public investment,
loans, or grants
Public competitive
bidding/tendering
Burkina Faso
Ethiopia
Gambia
Guinea
Haiti
Kenya
Kyrgyzstan
Madagascar
Malawi
Mali
Mozambique
Nepal
Rwanda
Tajikistan
Togo
Uganda
Zambia
Tanzania
LOW INCOME COUNTRIES
REGULATORY POLICIES AND TARGETS FISCAL INCENTIVES
PUBLIC
FINANCING
Table1.Renewableenergysupportpolicies(continued)
Some states/
provinces within
these countries have
state/provincial-level
policies but there is no
national-level policy.
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Contact us
André Boekhoudt
Head of Global Energy and
NaturalResourcesTaxPractice
T: +31 20 6 561358
E: [email protected]
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Publication name: Taxes and incentives for renewable energy
Publication number: 130491
Publication date: September 2013
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