Spain’s Form 232: November 2026 Filing Deadline and Increased Scrutiny of Related-Party Transactions

Companies and other taxpayers in Spain whose tax year follows the calendar year have until 30 November 2026 to submit Form 232 (Modelo 232), reporting relevant transactions carried out during the 2025 financial year. This reporting obligation is particularly important as the Spanish Tax Agency increases its scrutiny of related-party transactions and transfer pricing practices.

Form 232 is an annual information return used by the Spanish Tax Agency (Agencia Tributaria, or AEAT) to collect information on certain transactions between related parties, as well as transactions and arrangements involving non-cooperative tax jurisdictions.

Although Form 232 does not itself involve the payment of tax, failure to comply with its reporting requirements may expose businesses to tax penalties and additional scrutiny.

The reporting obligation applies to Spanish Corporate Income Tax taxpayers, certain non-resident taxpayers operating through a permanent establishment in Spain, and specific foreign entities under an income attribution regime with a presence in Spain.

For related-party transactions, the main reporting thresholds are:

• Over €250,000: transactions carried out with the same related person or entity during the tax year.
• Over €100,000: certain categories of specific transactions, including real estate transfers and transactions involving intangible assets.
• More than 50% of annual turnover: transactions of the same type valued using the same transfer pricing method, regardless of their individual amounts.

These thresholds are subject to specific conditions and exemptions, including certain transactions between companies belonging to the same Spanish tax consolidation group.

Form 232 also covers related-party transactions benefiting from the tax reduction applicable to income from certain intangible assets (commonly known as the patent box regime), as well as transactions and situations involving non-cooperative tax jurisdictions. These reporting requirements may apply regardless of the amounts involved.

Spain’s 2026 Annual Tax Control Plan identifies international related-party transactions as a priority area for tax audits and compliance checks.

Particular attention is being paid to corporate restructurings, transfers of intangible assets, intragroup services and financing arrangements between related entities.

Against this background, companies should ensure that the information reported in Form 232 is consistent with their accounting records and transfer pricing documentation, including the Local File where applicable.

Any discrepancies should be properly identified and supported by appropriate documentation.

For companies whose tax year ended on 31 December 2025, Form 232 must be filed between 1 and 30 November 2026.

Where the tax year does not coincide with the calendar year, the filing period is the month following the ten months after the end of the relevant tax period.

The return must be submitted electronically through the Spanish Tax Agency’s official online portal.

At ILIA ETL GLOBAL, we recommend reviewing related-party transactions, transfer pricing methodologies and supporting documentation before filing Form 232 to ensure regulatory compliance and minimise potential tax risks.

A proactive approach to transfer pricing compliance is essential for companies operating in Spain, particularly those belonging to international corporate groups.