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Transferable Tax Credit Facts and Statistics (2026)
Quick answer
Statutory figures: the §48E credit is 6% of basis, or 30% with prevailing wage and apprenticeship compliance; a §6418 credit transfers once for cash; recapture runs five years. Third-party data: Crux reported a $0.913 average price per $1.00 of 2026 investment credits and about $21 billion of transfers in the first half of 2026.
A citable reference of figures used on this site. Statutory figures come from the Internal Revenue Code, Treasury regulations and IRS guidance. Market figures are third-party data with the publisher and date shown; they are not Veritas quotes or predictions. Each figure links to its source.
Statutory and IRS figures
| Fact | Figure | Source |
|---|---|---|
| §48E base credit rate | 6% of eligible basis | 26 U.S.C. §48E |
| §48E rate with prevailing wage and apprenticeship, or under 1 MW AC | 30% | IRS: Clean Electricity Investment Credit; §48E |
| §48E bonus adders (domestic content, energy community) | Up to 10 percentage points each | §48E |
| Investment credit recapture period and schedule | Five years; 100%, 80%, 60%, 40%, 20% by year | 26 U.S.C. §50 |
| Number of times a §6418 credit can be transferred | Once; buyer must be unrelated; payment in cash | 26 U.S.C. §6418 |
| Excessive credit transfer addition | 20% of the excess, unless reasonable cause | §6418(g)(2) |
| Individual buyer limit | Purchased credit generally a passive activity credit; usable only against tax attributable to net passive income | IRS Transferability FAQ, Q15; Treas. Reg. §1.6418-2(f)(3) |
| Form used to limit passive credits | Form 8582-CR (individuals, estates, trusts); Form 8810 (corporations) | IRS Form 8582-CR |
| General business credit limit (§38(c)) | Net income tax minus the greater of tentative minimum tax or 25% of net regular tax above $25,000; about 75% of regular tax plus $6,250 when TMT is zero | 26 U.S.C. §38 |
| Carryover periods | General business credit: back 1, forward 20. Applicable credits (including §48E): back 3, forward 22 | 26 U.S.C. §39 |
| Net investment income tax | 3.8%; thresholds $250,000 joint, $200,000 other, $125,000 married filing separately | 26 U.S.C. §1411 |
| Material participation (one of seven tests) | More than 500 hours in the year | Treas. Reg. §1.469-5T |
| Real estate professional status | More than 750 hours and more than half of personal services in real property businesses | 26 U.S.C. §469(c)(7) |
| Rental real estate special allowance | Up to $25,000, phased out between $100,000 and $150,000 of AGI (not assumed to apply to purchased credits) | §469(i) |
| Trust and estate top rate, 2026 | 37% above $16,000 of taxable income | IRS Rev. Proc. 2025-32 |
| Wind and solar §48E/§45Y deadline | Construction begun by July 4, 2026, or placed in service by December 31, 2027 | Pub. L. 119-21 |
Market figures (third-party data)
| Metric | Figure | Publisher and date |
|---|---|---|
| Average 2026 price, investment tax credits | $0.913 per $1.00 of credit (typical historical range $0.920 to $0.925) | Crux, mid-year report, Aug. 20, 2026 |
| Average 2026 price, production tax credits | $0.930 per $1.00 of credit | Crux, Aug. 20, 2026 |
| Range at which most clean energy credits trade | About $0.88 to $0.96 per $1.00; early-2026 ITC average about $0.895 | Cenet Capital, Q4 2026 report, Oct. 4, 2026 |
| Credit transfers, first half of 2026 | About $21 billion | Crux, Aug. 20, 2026 |
| Tax equity and preferred equity, 2026 estimate | About $46.3 billion | Crux, Aug. 20, 2026 |
| Forecast annual credit supply through 2030 | Above $75 billion a year | Crux, Aug. 20, 2026 |
| Wind and solar safe-harbored before July 4, 2026 | More than 170 GW (Crux estimate) | Crux, Aug. 20, 2026 |
The two price sources measure differently (Crux reports market-wide averages; Cenet reports its own observations), so do not treat either as a quote. See §48E pricing and discount for what moves price.
How to cite this page
Veritas Tax Credits, "Transferable Tax Credit Facts and Statistics," veritastaxcredits.com/transferable-tax-credit-market-facts-and-statistics/, reviewed November 4, 2026. Please cite the original source linked next to each figure for statutory and market data, and tell us if you spot an error (see editorial standards).
Frequently asked questions
What do transferable tax credits sell for in 2026?
Crux reported a market-wide average of $0.913 per $1.00 of credit for 2026 investment tax credits in August 2026, and Cenet Capital reported most clean energy credits trading between about $0.88 and $0.96 in October 2026. These are third-party market data, not quotes.
How big is the credit transfer market?
Crux reported about $21 billion of credit transfers in the first half of 2026 and forecast annual credit supply above $75 billion through 2030. These are third-party estimates.
What is the §48E credit rate?
The base rate is 6% of eligible basis, or 30% with prevailing wage and apprenticeship compliance or for a facility under 1 MW AC, with bonus adders of up to 10 percentage points each.
- IRS: Clean Electricity Investment Credit (§48E)
- 26 U.S.C. §48E, Clean electricity investment credit (Cornell LII)
- 26 U.S.C. §50, Other special rules, recapture (Cornell LII)
- 26 U.S.C. §6418, Transfer of certain credits (Cornell LII)
- IRS: Elective pay and transferability FAQs, Transferability (Q4-Q15)
- 26 CFR §1.6418-2, Rules for making transfer elections (Cornell LII)
- IRS: About Form 8582-CR, Passive Activity Credit Limitations
- 26 U.S.C. §38, General business credit (Cornell LII)
- 26 U.S.C. §39, Carryback and carryforward of unused credits (Cornell LII)
- 26 U.S.C. §1411, Net investment income tax (Cornell LII)
- 26 CFR §1.469-5T, Material participation (temporary) (Cornell LII)
- 26 U.S.C. §469, Passive activity losses and credits limited (Cornell LII)
- IRS Rev. Proc. 2025-32 (2026 inflation adjustments, estate and trust rates)
- Pub. L. 119-21 (One Big Beautiful Bill Act), Congress.gov
- Crux: 2026 mid-year market intelligence report, 5 takeaways (Aug. 20, 2026), third-party market data
- Cenet Capital: Tax credit transfer market report, Q4 2026 (Oct. 4, 2026), third-party market data
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