Frequently asked questions about the 0 % control unit for photovoltaic modules

In December 2023, we reported on Requirements for VAT exemption for photovoltaic modules The BMF has recently published inquiries from interest groups (e.g., the Federal Association of Photovoltaic Austria), the answers to which may be helpful for the practical application of this benefit. Following are summaries of individual questions and answers.

• The zero tax rate only covers photovoltaic modules (modules for generating electrical energy). Hybrid collectors, which generate both electricity and heat, are not included.
• Regarding the uniformity of performance (from a tax point of view), the question arises whether, according to general principles of uniformity of performance, photovoltaic carport and photovoltaic fence elements are subject to the same tax treatment as photovoltaic modules. According to the BMF, this is not the case, as only photovoltaic system-specific components are subject to the zero tax rate as non-autonomous auxiliary services for the delivery of photovoltaic modules.
• Heat pumps are not subject to the zero tax rate – they do not share the sales tax fate of the delivery of the photovoltaic module, even if it is delivered or purchased together with a photovoltaic module.
• If part of the roof is also renovated during the installation of a photovoltaic system, the renovation of the roof is not eligible for aid (in accordance with the rules for auxiliary services).
• If two buildings are located on the same plot of land, is 35 kWp per building or 35 kWp in total applicable for both buildings, because first, both buildings are located on the same plot of land, and second, there is a spatial usage relationship? In conjunction with this, the question arises as to whether a photovoltaic system operator can claim the zero tax rate several times if he owns several plots of land, where the buildings benefiting from the tax incentive are located. Following the BMF, an operator can also have multiple photovoltaic systems, as a photovoltaic system is understood to be an autonomous, self-contained, functional, technically operational system. What is crucial and must be taken into account in this context is whether the system has its own switchgear and a separate meter reading point.

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