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Spanish form 190 calculator

Settle whether you have to file the annual withholding summary, under which code, why it does not reconcile with your four form 111s and when it really falls due.

The number of recipients decides the penalty, not the number of records
Do you have to file it?
Yes
Annex II code
A
Sub-code required?
No
Whether form 190 is due and which income code applies
The right formForm 190
Income codeA
Sub-code compulsory?No
Split between the State, Navarre and the Basque provinces?No
Was there withholding to carry to a 111?Yes
Required to file form 190?Yes
  • Code A carries no sub-code. Annex II requires one in nine of the twelve codes and this is not one of them.

Indicative calculation: this does not constitute financial advice. The annual summary is filed from a whole year of payroll and invoice data, and your accountant or payroll software is who holds it.

This does not compute the sub-codes one by one, the euro split of code E between the tax administrations, or forms 345 and 346, to which annex II itself sends in-kind pay with no payment on account and farming subsidies. Basque and Navarrese territory is out of scope.

1

Who files it, and the case almost nobody tells you about

Article 2.1 of Order EHA/3127/2009 reaches anyone who, being required to withhold under article 76 of the regulation, pays employment income, fees for professional, farming, livestock, forestry or flat-rate activities, prizes from draws, or the villagers’ forestry proceeds. And it adds three words that change everything: “exempt income included”. Since exempt income carries no withholding, article 108.1 of the regulation excuses the form 111 for a quarter in which only that kind of income was paid. The result is that a company can go a whole year without filing a single quarterly withholding return and still be required to file this summary.

2

The twelve codes, and why the same income can go in two of them

Annex II sorts the payments into twelve letter codes: A for ordinary payroll, B for pensions, C for unemployment benefits, E for directors and board members, F for courses and literary works, G for professional activities, H for farming and flat-rate activities, I for intellectual and industrial property where it is a non-professional business activity, J for non-residents’ image rights, K for prizes and L for exempt income and travel allowances. Nine of the twelve also require a numeric sub-code, and code A, which is the commonest, requires none. One recipient generates as many records as there are codes that apply to them.

3

Why it does not reconcile with the four form 111s, and how far it does

There is an identity you can write down. The income on form 190 equals the income on the four form 111s, plus the exempt income and travel allowances of code L, plus the prizes whose base fell short of 300 euros, minus the repayments made during the year, which are declared with a negative sign and zero withholding. Whatever is left after that sum is the only thing to go looking for. The withholding, by contrast, has to match to the cent, because article 108.2 calls the summary a return of the withholding “effected”, and that is the same withholding that was paid over quarter by quarter.

4

The deadline, computed rather than quoted

Article 108.2 of the regulation and article 5 of the Order give as the general rule the first twenty natural days of January, and extend the window from the 1st to the 31st in three cases, the third of which is electronic filing. Since article 12 of Order HAP/2194/2013 left paper filing “(Suprimida)”, electronic filing is the only lawful channel: the exception applies always and nobody can trigger the general rule. And both dates move to the next working day when they fall on a non-working one, under article 30.5 of Law 39/2015.

5

And the penalty, which sits on a different article from the one most people cite

Not filing it is article 198.1, fourth paragraph: 20 euros per item or set of items referring to one same person, with a minimum of 300 and a maximum of 20,000. Article 198.2 halves the penalty and both limits where the return is filed before the tax office asks for it. Filing on time with the wrong code or tax number is article 199.4: 200 euros per affected recipient, with no maximum. With the wrong amounts, article 199.5: up to 2% of what was misdeclared, minimum 500 euros. And the 30% agreement reduction reaches none of the three, because article 188.1 reserves it to articles 191 to 197.

Worked example

An example, and it is the calculator’s opening state. A company pays payroll to twelve people during 2025. Its four form 111s declare 240,000 euros of income and 36,000 of withholding. Its form 190 declares 248,000 euros of income and the same 36,000 of withholding, because it includes 8,000 euros of travel allowances within the limits of article 9 of the regulation, which go in code L and from which nothing was withheld. The withholding matches, the 8,000-euro difference is accounted for and the residue is zero: the summary is right. The deadline fell on 2 February 2026, not 31 January, because that day was a Saturday. And had the same company filed with the wrong code for three of its twelve employees, article 199.4 would cost it 600 euros, against the 300-euro minimum it would pay for not having filed at all.

Frequently asked questions

When is Spanish form 190 filed?
From 1 January to 31 January of the following year, and that 31st moves to the next working day where it falls on a Saturday, a Sunday or a holiday. The 2025 summary therefore fell due on Monday 2 February 2026, which is the date under which the Spanish Tax Agency’s taxpayer calendar publishes it, and the 2026 one falls due on Monday 1 February 2027. Form 390 falls due the very same day, because its own 30 January 2027 is also a Saturday.
Why does my form 190 not match my four form 111s?
Because it does not have to match on income. The summary reports the income paid “exempt income included”, and exempt travel allowances, exempt severance pay and the thirty-two sub-codes of code L have never been on a quarterly return, because nobody withheld from them. Nor have prizes whose base fell short of 300 euros. And repayments subtract from the summary without moving any form 111. What does have to match to the cent is the withholding.
What are the form 190 income codes?
Twelve, in annex II of the Order: A employees in general, B pensioners and public pensions, C unemployment benefits and subsidies, D the pre-2013 lump-sum benefits when repaid, E directors and board members, F courses, lectures and literary works, G professional activities, H farming, livestock, forestry and flat-rate activities, I intellectual or industrial property and the letting of movable property and businesses, J non-residents’ image rights, K prizes and villagers’ forestry proceeds, and L exempt income and travel allowances within the exempt limits. Nine of the twelve require a sub-code.
Do I have to file form 190 if I withheld nothing?
It depends on what you paid, not on how much you withheld. If during the year you only paid exempt income or allowances within the legal limits, you filed no form 111 at all (article 108.1 does not admit a nil return where no income subject to withholding was paid) and you do have to file form 190, because article 2.1 reaches exempt income. If you paid none of the income that article lists, there is no obligation.
What happens if I file form 190 late?
Article 198.1, fourth paragraph, of the General Tax Act applies: 20 euros for each recipient who should have appeared, with a minimum of 300 euros and a maximum of 20,000. If you file of your own accord, before the tax office asks, article 198.2 halves the penalty and both limits, so the minimum drops to 150 and the maximum to 10,000. On whatever results, article 188.3 takes 40% off if you pay on time and do not appeal. And because it is an information return there is no article 27 surcharge: there is no amount payable to compute one on.
Does filing it wrong cost more than not filing it?
Yes, and considerably more. The code, the tax number and the accrual year are non-monetary data, and article 199.4 penalises them at 200 euros per affected recipient with NO maximum at all, while article 198.1 caps a failure to file at 20,000 euros. With two hundred wrongly coded employees that is 40,000 euros, ten times what filing nothing would have cost. And article 199.6 doubles that figure for a repeated offence without ever reaching article 198, so the repeat non-filer is not doubled and the repeat mis-filer is.
What is the difference between a supplementary and a substitute return?
Article 11 of the Order separates them by effect. A supplementary return adds payments not previously declared, or amends and cancels particular details of payments already declared, which survive in the part not affected. A substitute return replaces the earlier one’s content in full. And there is one case where you cannot choose: to cancel a declared payment entirely you must file a substitute return, because a supplementary one only amends or cancels particular details.
How is back pay from an earlier year declared?
With its own record, and the “Ejercicio devengo” field at positions 148 to 151 of annex II filled with the four digits of the year the income accrued. Where one person was paid amounts accrued in several years, they must be split into as many records as there are years, because each record can only reflect payments accruing in one same year. In every other case the field is filled with zeros.
Why does my accountant say form 190 is due on 31 January?
Because that is the deadline for electronic filing, and also the one almost every guide prints. The general rule in article 108.2 of the regulation is 20 January, eleven days earlier; the 31st is reached only where the return is filed online, on machine-readable media or generated with the tax office’s own print module. The curious part is that paper filing has been suppressed since article 12 of Order HAP/2194/2013, so the exception is met every time and nobody can trigger the general rule any more.
Does the rent on my office go on form 190?
No. The annual summary of withholding on urban property leases is form 180, which is to form 115 what form 190 is to form 111, and it falls due the same day. Withholding on interest and dividends goes on form 193. Form 190 only covers the employment and business income listed in article 2.1 of its Order, plus prizes and villagers’ forestry proceeds.

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Author: Thorben Rasmus Idel · Reviewed by: Nahar Geva · Last reviewed: