Modelo 347 Spain: Who Files, Exclusions and Deadlines

Modelo 347 is Spain's annual information return for certain transactions with third parties. Businesses and professionals generally consider each person or entity with whom their operations exceeded €3,005.06, including VAT, during the calendar year. But the threshold is not the first or only test: filer-level exemptions and transaction-level exclusions can remove the obligation before any amount is reported.

The practical rule for Modelo 347 Spain is to work through the tests in this order:

1. Confirm that the business or professional is required to file.
2. Aggregate the year's operations separately for each counterparty, including VAT where the rules require it.
3. Remove operations already captured through another periodic information return or an excluded customs route.
4. Allocate the remaining reportable amount under the quarterly or annual breakdown rules.
5. Submit the return electronically from 1 February, using the effective closing date in the relevant AEAT taxpayer calendar.

Crossing €3,005.06 does not make every invoice with that counterparty reportable. Modelo 347 operates as a residual declaration: it captures qualifying third-party operations that have not already been reported to the Spanish tax authority through a more specific route. A professional fee reported with coincident information on Modelo 190, for example, is not reported again merely because the annual total exceeds the threshold.

Nor is Modelo 347 a tax-payment return. It supplies counterparty and transaction information that AEAT can compare with other records. AEAT's English overview of Form 347 confirms the general €3,005.06 VAT-inclusive threshold, the February filing period and the electronic submission requirement.

Who must file, and who is exempt before the threshold test

The general filing population is made up of businesses and professionals carrying on economic activities that exceed the counterparty threshold after the relevant exclusions are applied. AEAT's guidance on who must submit Form 347 also brings particular non-commercial bodies into scope for specified transactions. These include property-owner communities and qualifying social entities for certain acquisitions, public administrations for grants and assistance, and entities that collect designated professional fees or intellectual-property rights on behalf of members.

Before testing individual transaction populations, check whether the filer is excluded. AEAT identifies several filer-level cases, including:

• A person or entity without its economic headquarters, a permanent establishment or tax domicile in Spain under the conditions set out in the rule.
• Certain taxpayers using the personal income tax objective-estimation method together with specified VAT regimes. This exclusion is qualified: invoiced operations and, for taxpayers under the simplified VAT regime, acquisitions that must be entered in the received-invoice book can still matter.
• A taxpayer whose operations with every person or entity remain at or below €3,005.06 for the year, subject to the separate €300.51 rule for entities collecting specified fees or rights for third parties.
• A taxpayer whose activities consist exclusively of operations outside the reporting obligation.
• A taxpayer required throughout the year to keep VAT registration books through the Immediate Supply of Information system, known as SII.

The AEAT page on exclusions from the filing obligation treats SII at the level of the taxpayer. In other words, the Modelo 347 SII exemption is not a transaction-by-transaction filter for a business that otherwise has to file. It removes the annual filing obligation for a taxpayer that meets the stated SII condition.

Labels alone do not settle the question. Being self-employed, small or foreign-owned is not itself an exemption, and falling below the threshold with one customer says nothing about a different counterparty. The filer test should be documented before invoice-level exclusions are applied, especially where a business changed VAT regime, establishment status or SII obligations during the year.

The exclusion table: what leaves Modelo 347 and where it goes

Article 33.2(i) of the RGAT supplies the organising rule: an operation is excluded when there is a periodic obligation to provide that information to AEAT, it has been included in another specific declaration, and the content is coincident. The AEAT list of operations excluded from Modelo 347 also covers specified imports, exports, territorial shipments and other categories.

The following table is a routing aid, not a substitute for checking the facts of a transaction:

Population or operation	Normal reporting route	Modelo 347 treatment	Qualification
Professional invoices carrying IRPF withholding	Modelo 190	Excluded when the coincident information is reported through Modelo 190	Do not add the invoice again at a gross IVA-inclusive amount merely because the counterparty total exceeds €3,005.06
Business-premises rent subject to withholding	Modelo 180	Excluded where the periodic return contains the coincident information	Confirm the property and payment facts; not every lease follows the same withholding treatment
Intra-EU supplies and acquisitions	Modelo 349	Not duplicated in Modelo 347 where the specific information-reporting obligation applies	Check that the operation is within Modelo 349 rather than assuming every cross-border invoice follows this route
Imports, exports and specified shipments involving mainland Spain, the Balearic Islands, the Canary Islands, Ceuta or Melilla	Customs declaration or DUA records	Excluded in the circumstances listed by AEAT	Territorial and permanent-establishment qualifications matter
Taxpayer required throughout the year to keep VAT books through SII	SII	No Modelo 347 filing obligation under the stated filer exemption	This is a taxpayer-level result, not an invoice-level destination
Ordinary domestic customer or supplier operations not reported through a more specific route	Modelo 347 candidate	Include if the filer is in scope, the operations are not otherwise excluded and the annual counterparty threshold is exceeded	Aggregate the calendar-year amount before applying the reporting threshold

The professional-invoice row corrects a recurring error. If coincident information about fees subject to withholding is included in Modelo 190, the operation is excluded from Modelo 347. The invoice is not reintroduced at its gross amount including IVA. The BOE explanation of the residual-declaration rule describes the exclusion for operations already included in a different specific return with coincident content. For the document-level withholding mechanics, see IRPF withholding on Spanish professional invoices.

The word coincident prevents the table from becoming a collection of blanket shortcuts. A form number associated with the counterparty is not enough on its own. The actual operation must fall within that reporting obligation and the required information must overlap. Mixed supplies, partly reportable relationships and unusual establishment facts should be checked against the current AEAT instructions and, where material, a Spanish tax adviser.

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How to calculate the €3,005.06 annual counterparty amount

Apply the threshold to the calendar year's qualifying operations with each person or entity, after removing filer-level and transaction-level exclusions. It is not a per-invoice limit. Purchases and sales are calculated under separate operation keys and must not be netted against each other when applying the €3,005.06 threshold. Ten reportable purchase invoices of €400 from the same supplier produce an annual acquisition total of €4,000 and therefore cross the general threshold; ten invoices of that amount spread across ten unrelated suppliers do not.

AEAT's instructions on transaction amounts define the amount as the total consideration calculated under the VAT taxable-base rules. For operations subject to and not exempt from VAT, the total includes the VAT charged or incurred, any equivalence surcharge, and the relevant compensation under the special agricultural, livestock and fishing regime. Refunds, discounts, bonuses, void transactions and price changes are reflected under the detailed adjustment rules rather than left in the original gross total. VAT-base changes following a bankruptcy order also affect the declared amount.

Advances require their own treatment. AEAT says customer and supplier advances enter Modelo 347; when the transaction is later completed, the amount then declared is reduced by the advance already reported, subject to the annual counterparty test. The temporal-attribution instructions also contain separate rules for the VAT cash-accounting regime, public grants and cash collected after the original reporting year.

A useful preparation schedule retains more detail than the final return: counterparty NIF and legal name, invoice or supporting-document date, registry-book period, taxable base, VAT, gross amount, operation key, credit-note linkage and the reason for any exclusion. Reliable identifiers matter because Spain's VAT invoice requirements determine much of the underlying document evidence, while Modelo 347 consolidates that evidence at counterparty level.

The annual total decides whether the general €3,005.06 threshold is exceeded. The period breakdown describes when the reportable amount belongs. Keeping those tests separate prevents a low-value quarter from being dropped when the full-year counterparty total is above the limit.

Quarterly breakdowns and legitimate counterparty mismatches

Modelo 347 normally reports an annual counterparty total broken down by quarter. The annual figure establishes that the reporting threshold has been crossed; the quarterly fields show when the included operations are attributed. A counterparty does not fall out of the return merely because each individual quarter is below €3,005.06.

The AEAT breakdown rules identify information that is supplied on an annual basis instead. This includes cash amounts, information declared by taxpayers applying the special VAT cash-accounting regime, information required from property-owner communities under the stated rule, and recipients' operations subject to the special cash regime.

For ordinary operations, attribution follows the period in which the invoice or supporting document should be entered in the relevant register. That can produce a legitimate difference between the supplier's and customer's quarters. A supplier might enter an issued invoice in the quarter in which it was issued, while the customer records the received invoice in the next quarter under the applicable registry rule. The two parties can therefore show the same valid annual amount against different quarterly periods.

Cash-basis operations follow their specific total or partial collection and payment rules, not the standard invoice-register timing. Adjustments can also land in a later quarter than the original transaction. AEAT's amount rules require refunds, discounts, void transactions and price modifications to be reflected in the quarter in which the modifying event occurs when the stated conditions are met.

Reconcile in an order that preserves valid timing:

1. Compare the annual counterparty totals.
2. Compare the transactions each party excluded and the operation keys used.
3. Check credit notes, advances and other later adjustments.
4. Investigate invoice-register dates and cash-basis timing.

A quarterly difference is a prompt to inspect the records, not proof of an error. Changing a valid registry period solely to force both parties' quarters to match can create a new compliance problem while concealing the original timing difference.

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Prepare, file and correct the return

A controlled preparation file makes the exclusion decisions reviewable. Start from a frozen calendar-year dataset, then:

1. Normalize each counterparty's NIF and legal name.
2. Mark filer-level status and give every removed transaction a specific exclusion code.
3. Aggregate the remaining purchases and sales by counterparty and operation key.
4. Apply the annual threshold, then allocate reportable amounts to quarters or the applicable annual-only field.
5. Reconcile the schedule to VAT books, withholding returns, customs records and credit notes.
6. Retain the final schedule, validation output and filing receipt.

For teams that need a deeper invoice-ledger process, the Spanish-language guide to reconciling Modelo 347 with invoice books covers that work without changing the obligation and exclusion tests described here.

Submission is electronic. Under AEAT's current filing-method instructions, natural persons who are not assigned to the DCGC or UGGE may use Cl@ve or an accepted electronic certificate. Legal entities, public administrations, specified large-taxpayer categories and the other named filers use a recognized electronic certificate. The declarant can file directly or authorize a representative or social collaborator.

AEAT provides two submission routes:

• The web form, for declarations containing up to 40,000 records.
• File submission through TGVI Online.

The correction method depends on the route used. In the web form, the filed declaration can be retrieved, corrected and submitted again as a complete return. AEAT warns that the new submission replaces the earlier one, so the corrected filing must contain every record that should remain declared, not only the changed items.

File-based corrections use supplementary and substitute declarations. A supplementary file adds records that were completely omitted from an earlier return. A substitute declaration cancels and replaces the prior declaration as a whole; AEAT's process requires the original to be cancelled through the substitution service before the replacement file is submitted. The relevant prior 13-digit supporting number must be retained. AEAT's completion instructions distinguish an addition of omitted data from a full replacement of inaccurate or erroneous data.

February deadlines and the penalties that depend on what went wrong

AEAT's filing-period rule requires Modelo 347 to be submitted from 1 February for operations in the preceding calendar year, with the effective closing date determined by the applicable taxpayer calendar. If a technical problem makes online submission impossible within that period, the same guidance allows filing during the following four calendar days. That provision should not be treated as a routine extension.

Calendar effects change the final effective date in some years. For a verified past example, the return covering the 2025 calendar year appeared under AEAT's deadline of 2 March 2026. A deadline for a later return should not be projected from that example. Check the taxpayer calendar for the filing year and record the applicable date in the preparation timetable.

There is no single automatic "Modelo 347 penalty." The consequence depends on whether the problem is lateness, inaccurate information, an ignored authority request or failure to use the required electronic channel.

Information returns form part of a much wider control environment. AEAT's 2024 annual report on internal tax controls states that Spain's Tax Agency concluded nearly 2 million internal tax audits in 2024, 4.39% more than in the previous year. That figure covers internal tax control activity generally; it is not a count of Modelo 347 audits or a basis for predicting enforcement in an individual case.

For an information return filed late without economic loss, Article 198 of Spain's General Tax Law provides a fixed penalty of €20 for each omitted item or set of data relating to the same person or entity, with a minimum of €300 and a maximum of €20,000. When the return is filed voluntarily before an AEAT request, the penalty and both limits are halved. The same article contains a specific treatment for a late supplementary or substitute return filed voluntarily after an incomplete or inaccurate return was submitted on time.

Inaccurate monetary data is addressed separately. Article 199 uses a fact-dependent proportional structure of up to 2% of the operations omitted or reported incorrectly, with a €500 minimum; the percentage varies with the proportion of affected operations. Non-monetary data, responses to individualized requests and use of a non-electronic method where electronic filing is mandatory have different rules. The consolidated General Tax Law should be checked in its current form, and a material error warrants case-specific advice before a correction is filed.