Spanish form 232 checker
Tells you whether your Spanish company has to file form 232, which of the five triggers in article 2 catches it, what day the window closes, and what a mistake costs. Two of those five triggers carry no threshold at all.
| Trigger | Threshold | Met? |
|---|---|---|
| Total with one related party (art. 2.1.a) | €250,000 | No |
| Specific operation, by type (art. 2.1.b) | €100,000 | Yes |
| Same type and same method (art. 2.3) | 50.0% | No |
| The art. 23 LIS reduction (art. 2.4) | No threshold | No |
| Non-cooperative jurisdiction (art. 2.5) | No threshold | No |
- A «specific operation» is one of the five categories excluded from the simplified documentation content (arts. 18.3 LIS and 16.5 RIS). The fourth is property, and there the statute says «operations ON» while the regulation says «operations TRANSFERRING»: a lease fits the first and not the second.
- Article 2.2 leaves out transactions inside a tax consolidation group, those of AIEs and UTEs (other than art. 22 LIS ones) and those within a public offer. Subtract those before typing.
More cases
Article 2.3 applies «irrespective of the amount» when operations of the same type using the same valuation method exceed 50% of turnover.
It does not model the art. 18.4 LIS valuation methods, the country-by-country report of art. 13.1 RIS and its form 231, the content of the art. 15 and 16 RIS documentation, or the foral regimes. There are 5 categories of specific operation. The only entry added in 2026 is the Federación de Rusia, por lo que respecta al régimen fiscal perjudicial (international holding companies).
Five independent triggers, not three thresholds
Article 2 of the Orden splits the obligation into five paragraphs that do not add up to each other: one is enough. The first three carry a figure: EUR 250,000 with one related person or entity, EUR 100,000 for each type of specific operation, and 50 per cent of turnover for operations of the same type that also use the same valuation method. The other two carry none: paragraph 4 catches anyone claiming the article 23 reduction on income ceded to a related party, and paragraph 5 anyone dealing with, or holding securities in, a non-cooperative jurisdiction, "irrespective of the amount".
The thresholds are strict and each is measured separately
The Orden says "exceeds", so landing exactly on EUR 250,000 or EUR 100,000 does not trigger the form by that route. And each test has its own scope: the first aggregates every transaction with one counterparty, the second aggregates each TYPE of specific operation, and the third measures a proportion rather than an amount. Removing a transaction can take you out of one test and leave you in through another.
What a "specific operation" is, and why it decides more than it looks
Paragraph 1.b) defines it by negation: they are the operations excluded from the simplified documentation content listed in article 18.3 of the act and 16.5 of the regulation. There are five categories (activities under the objective estimation method with entities held at 25 per cent, transfers of a business, transfers of unlisted shares, property and intangibles) and the fourth is the one most people touch without realising. Selling premises to your own company for EUR 120,000 files form 232 even though the EUR 250,000 threshold is nowhere near.
The two lists the Orden cites as one do not say the same thing
Article 18.3 of the act says "operations on property" and article 16.5 of the regulation says "operations transferring property". A lease of premises between the company and its director is the first and is not the second, and the Orden cites the two together as though they were one list. The calculator does not resolve the divergence silently: it applies the reading in the act, which is broader and of higher rank, and says so.
Which jurisdictions count depends on when your period starts
Orden HAC/649/2026 removed six entries with effect from 28 June 2026 and added the Russian international-holding regime from 28 December of the same year. But its second final provision applies them "to the other taxes whose tax period begins from that moment", and Spanish corporation tax is one of those. For a calendar-year company that means Gibraltar is still a non-cooperative jurisdiction for the 2026 period and stops being one in 2027. That is why the checker asks for the START date of the period rather than a year.
The deadline is a whole month, and it lands long after form 200
Article 4 gives "the month following the ten months after the tax period closes". It is not a single day: the sole transitional provision writes it as "from 1 to 30 November". For a year ending 31 December 2025 the window is the whole of November 2026, closing on the 30th. And form 200 for the same period was due on 27 July, so by the time this information return is filed the tax assessment has been in for months.
And the penalty is not the one almost everyone quotes
Article 18.13 of the corporation-tax act, with its EUR 1,000 per item and EUR 10,000 per set of items, penalises the failure to produce the documentation that must be "kept at the disposal" of the tax authority. That is the file you keep and hand over on request. Form 232 is filed, so the general regime applies: article 198 of the General Tax Act if you do not file, and article 199 if you file with incorrect data. And article 199 has no ceiling, while article 198 stops at EUR 20,000.
Worked example
A calendar-year company sells premises to its director in 2026 for EUR 120,000 and has no other related-party transaction reaching EUR 250,000. The first test is not met. The second is: property is one of the five specific operations and EUR 120,000 exceeds EUR 100,000, so it files form 232. The window opens on 1 November 2027 and closes on the 30th, four months after form 200 for that same year fell due. If it does not file and the tax office asks, with twelve related persons or entities the article 198.1 penalty computes to EUR 240 and rises to the EUR 300 floor; if it files late of its own accord, article 198.2 halves the penalty and both limits and it stops at EUR 150.
Frequently asked questions
Do I have to file form 232 if I do not reach EUR 250,000?
Does holding units in a fund based in a tax haven make me file?
Is Gibraltar still on the list?
Is my director a related party if they hold no shares?
When is form 232 for 2025 due?
What does not filing cost?
Can filing it badly cost more than not filing it at all?
Can income and payments be netted off?
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Sources
- Orden HFP/816/2017, de 28 de agosto, por la que se aprueba el modelo 232: obligados (art. 2), contenido (art. 3) y plazo (art. 4) · Boletín Oficial del Estado
- Ley 27/2014, del Impuesto sobre Sociedades, artículo 18: qué es una operación vinculada, la documentación específica y su régimen sancionador · Boletín Oficial del Estado
- Real Decreto 634/2015, reglamento del Impuesto sobre Sociedades, artículos 13 y 16: la información sobre operaciones vinculadas y el contenido simplificado · Boletín Oficial del Estado
- Orden HFP/115/2023, de 9 de febrero: la relación de jurisdicciones no cooperativas, en su redacción vigente · Boletín Oficial del Estado
- Orden HAC/649/2026, de 21 de junio: suprime seis jurisdicciones y añade el régimen ruso de holdings, con dos fechas de efectos distintas · Boletín Oficial del Estado
- Ley 58/2003, General Tributaria, artículos 188, 198 y 199: las sanciones de las declaraciones informativas y sus reducciones · Boletín Oficial del Estado
- Calendario del contribuyente 2026, hasta el 30 de noviembre: el modelo 232 del año 2025 para entidades cuyo período coincide con el año natural · Agencia Tributaria
Author: Thorben Rasmus Idel · Reviewed by: Nahar Geva · Last reviewed: