The income codes on Spanish form 190, and why it does not match your 111s

The short answer

Form 190 lists, person by person, everything your company paid during the year in employment income and in certain business income. Each payment is sorted into one of twelve letter codes, and nine of them also require a two-digit numeric sub-code².

And there are three words in article 2.1 of the Order that decide almost everything else: the income is reported “exempt income included”¹. Exempt income carries no withholding, so it has never been on a form 111. That is where the rule this article exists to explain comes from:

The withholding on form 190 has to match the withholding on your four form 111s. The income figures do not.

It is the exact opposite of form 390, the annual VAT summary, which is filed a few days earlier and does have to reconcile with the four quarterly VAT returns of the year.

The twelve income codes

Three details in that table deserve a sentence each.

Code A carries no sub-code, and it is the one generating most records in any company. The SUBCLAVE field of annex II lists the nine codes that require one and adds that “in payments corresponding to codes other than those mentioned, this field shall not be completed”².

Code D is dead and survives for exactly one purpose. Since 1 January 2013 the lump-sum unemployment benefit has been fully exempt and is reported under code L, sub-code 13. Code D survives solely to declare repayments of amounts wrongly received in years before 2013 that were originally declared under it². It is a code that only reports the undoing of something it no longer reports.

And intellectual property can go in three different codes, depending on how the income is characterised for whoever receives it: code F if it is employment income, code G if it is their professional activity, and code I if it is a business activity that is not professional². The payer has to know something about the recipient’s own tax position in order to complete its own return correctly.

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

The difference is not an impression. It is a sum you can write down.

income on the 190 = income on the four 111s
                  + exempt income and travel allowances (code L)
                  + prizes with no withholding (code K, base below 300 euros)
                  − repayments made during the year

Each of the three items has its own rule:

1. Code L. It covers travel and subsistence allowances in the amounts exempt under article 9 of the regulation, and exempt income that counts as employment income². There are thirty-two sub-codes: 01 for allowances, 05 for exempt severance pay, 10 for scholarships, 15 for work performed abroad, 13 for the lump-sum unemployment benefit, 29 for the minimum living income. Not a cent was withheld from any of them.
2. Code K. Its description expressly includes prizes “on which there is no duty to withhold or make a payment on account because the withholding base does not exceed 300 euros”². A 200-euro prize in a staff raffle is reportable and has generated no withholding at all.
3. Repayments. They are reported under the same code they were originally declared under, with the letter “N” in the sign field and zero in the withholding field². They subtract from the summary without ever having moved a quarterly return.

The withholding, by contrast, does have to match. Article 108.2 of the regulation calls form 190 “an annual return of the withholding and payments on account effected”⁴, and that is the same withholding paid over quarter by quarter. Any difference there is an error, in one of the two returns.

What that means in practice. Faced with a mismatch, the first move is not to file a correction: it is to check whether the difference is exactly the sum of those three items. In any company with travel allowances, a difference is the normal state of affairs.

And there is an extreme case worth keeping in mind. If for a whole year a company only paid allowances within the legal limits, it filed no form 111, because article 108.1 does not admit a nil return where no income subject to withholding was paid⁴, and it is required to file form 190. A whole year with no quarterly returns and a compulsory annual summary.

The same payment can split across two codes, and sometimes the payer decides the code

The description of code L carries an instruction almost nobody applies: where the exemption is subject to quantitative limits and the company paid above them, “the excess shall be included under whichever code and, where applicable, sub-code of the others corresponds”².

Take the subsistence allowance for a day trip inside Spain, where the exempt limit is 26.67 euros a day. If the company pays 40 euros a day:

One payment, two records, and only one of the two has been withheld from.

And there is income whose code is decided not by its nature but by who makes the transfer. Sick pay paid directly by the employer to the worker, under its collaboration agreement with the social security, goes under code A. Where the social security or the collaborating mutual pays it, it goes under code B, sub-code 01². The same benefit, the same person and the same amount, in two different codes.

The five-way split that only board members get

Positions 323 to 387 of annex II open a block of five boxes: the State, the Chartered Community of Navarre and the provincial councils of Araba, Bizkaia and Gipuzkoa. And the annex says this field “shall be completed exclusively in the case of payments under code E”².

The reason is that where a company operates both in common territory and in foral territory, the withholding on its directors’ pay is paid over in proportion to the company’s turnover, under the Economic Convenio with Navarre and the Economic Concierto with the Basque Country. The annex requires the return to say how much went to each administration, and the five boxes have to add up to what the two general withholding boxes declare²: an identity the form checks against itself.

The striking part is the asymmetry. The withholding on an employee of that same company goes wholly to one administration. The withholding on whoever sits on the board is split five ways, and the proportion is the very magnitude, turnover, that decides the company’s corporation-tax instalments.

The deadline that only exists on paper

Article 108.2 of the regulation sets as its general rule the first twenty natural days of January, and extends the window from the 1st to the 31st where the return is filed on machine-readable media or generated with the tax authority’s own print module⁴. Article 5 of the Order repeats the structure and adds a third letter: electronic filing, which “for the purposes of the filing deadline” counts as filing on machine-readable media³.

Now set those two rules beside article 12 of Order HAP/2194/2013, which governs how information returns may be filed and whose letter b), the paper one, today reads “(Suprimida)”⁵. Electronic filing is not an option: it is the only one. So the exception is met every time and nobody can trigger the 20 January general rule. Eleven days of deadline that exist, quite literally, on paper.

And that 31 January moves to the next working day where it falls on a Saturday, a Sunday or a holiday, under article 30.5 of Law 39/2015¹¹. It falls at a weekend twice running:

The 2025 summary was not filed in January, and the 2026 one will not be filed in January either. That is the date under which the Spanish Tax Agency’s taxpayer calendar publishes it: in 2026 the calendar does have a “Hasta el 31 de enero” page and form 190 is not on it. It sits on the next one, “Hasta el 2 de febrero”, alongside forms 180, 188, 193, 194, 196 and 270¹⁰.

There is a detail you only notice by looking at 2027. Form 390, the annual VAT summary, falls due on 30 January, a day earlier than this one. In 2027 the 30th is a Saturday and the 31st a Sunday, so both annual summaries, of two different taxes, fall due on the same Monday, 1 February.

Finally, the technical-failure tail. The form’s own Order, in articles 8.2 and 9.2, grants three calendar days where technical reasons prevented a timely filing³. The general Order on information returns grants four in its article 17.2, expressly applies to form 190 through its article 1.3, and repeals “any provisions of equal or lower rank that conflict with it”⁵. Four is the answer, and it is the one the Tax Agency itself publishes on this form’s deadline page⁹.

Filing it wrong costs more than not filing it, and has no ceiling

This is the part no guide covers, and it comes from comparing two consecutive articles.

Not filing it is article 198.1, fourth paragraph: 20 euros for each item or set of items referring to one same person, with a minimum of 300 euros and a maximum of 20,000⁶. Note the unit: the person, not the record. All the code splitting that makes the file longer does not make the penalty larger.

Filing on time with the wrong code or tax number is article 199.4: 200 euros for each affected recipient, and that article sets no maximum at all⁷.

Ten times more for filing it with a wrong item than for not filing it. And the asymmetry stretches: article 199.6 doubles the amount for a repeated offence, but only the amounts in paragraphs 4 and 5, so the repeat non-filer is not doubled and the repeat mis-filer is⁷.

Two more points, in the other direction. Article 198.2 halves “the penalty and the minimum and maximum limits” where the return is filed before the tax authority asks for it⁶, so the minimum drops to 150 euros and the ceiling to 10,000. And on whatever results, article 188.3 takes 40% off for prompt payment. The 30% agreement reduction does not reach it, because article 188.1 grants it to “the pecuniary penalties imposed under articles 191 to 197”⁷.

A worked example with real numbers

A company with twelve employees closes 2025 like this:

At first glance it is out by 8,000 euros. It is not out at all. During the year the company paid 8,000 euros of subsistence and mileage allowances within the limits of article 9 of the regulation, which go under code L, sub-code 01, and from which nothing was withheld. The sum closes: 240,000 plus 8,000 is 248,000, the residue is zero, and the withholding matches to the cent, which is the only compulsory part.

That summary fell due on 2 February 2026, not 31 January, because the 31st was a Saturday.

And suppose the company filed on time but coded the allowances of three of its twelve employees as code A. Article 199.4 penalises those three recipients at 200 euros each: 600 euros, reducible to 360 with prompt payment. Had it not filed at all and been formally asked for the return, twelve recipients at 20 euros is 240, raised to the statutory minimum of 300⁶. Filing the summary and getting three codes wrong costs twice as much as not filing it.

What changed in the 2025 summary

Order HAC/1432/2024 of 11 December applies for the first time to the form 190 for 2025, the one filed in January and February 2026⁸. Two new things:

• A field at position 388, “Excesos entrega acciones empresas emergentes”, completed only under code A and only where there is in-kind pay, to flag that the valuation includes shares in a start-up above the amount exempt under the second paragraph of letter f) of article 42.3 of the Tax Act².
• A breakdown of the code C sub-codes separating contributory unemployment benefits from non-contributory ones.

Any guide written before December 2024 describes a file with one field fewer.

What this summary does not cover

Three hand-offs that annex II itself establishes, and that explain why “everything I paid” is not an accurate description of form 190:

• In-kind pay with no duty to make a payment on account under article 102.2 of the regulation, that is contributions to pension plans, provident societies and occupational pension schemes, falls outside and is declared on form 345².
• In the farming activities of code H, subsidies and compensation are not included: they go on form 346².
• Prizes subject to the special levy on certain lotteries and betting fall outside code K².

And two neighbours it is often confused with. The annual summary of withholding on urban property leases is form 180, which is to form 115 what this is to form 111, and it falls due the same day¹⁰. The one for withholding on interest and dividends is form 193.

One last duty that is not a form but travels in the same envelope: article 108.3 of the regulation requires a certificate to be issued to each taxpayer showing the withholding practised and the other details that appear in the annual summary, and to be made available to them “before the filing window for this tax opens”⁴. It has no date: it has an event, and the income tax campaign opens by ministerial order each year.