What Spanish form 180 is, and how many records yours carries

The short answer

Form 180 is the annual summary of the withholding a tenant practised during the year on the rent of urban property in Spain. It is to form 115 what form 190 is to form 111, and both pairs fall due on the same day.

What sets it apart from any other annual summary is the unit of declaration. It carries no record per lease, and none per landlord:

You must include on form 180 as many records as there are properties with a different cadastral reference in the letting⁴.

A tenant with one landlord and three premises files three records. And because leases usually state a single price, the immediate consequence is that a withholding base has to be split between several properties. Of the eight frequently asked questions the Spanish tax office publishes about this form, seven are about exactly that.

Who files it, and why its own Order does not say

The Order of 20 November 2000 is a curiosity in this cluster: it approves form 115 and form 180 in a single norm². Paragraphs one to seven belong to the quarterly return and paragraphs eight to seventeen to the annual one. Form 111 and form 190, by contrast, are approved by separate Orders.

That Order has a paragraph two headed “who must file form 115” and no equivalent at all for form 180. The duty comes straight from the regulation:

The withholder or party required to make a payment on account shall file, within the first twenty natural days of January, an annual return of the withholding and payments on account effected¹.

In practice that means form 180 is filed by whoever filed form 115s during the year, and for the same lettings. Those required to withhold are businesses and professionals, legal persons and entities without legal personality that pay income for the letting of urban property: a private individual letting their home does not withhold and files nothing.

And if none of the income paid was subject to withholding, there is nothing to summarise either. Article 75.3.g) of the regulation takes out of withholding, among other cases, lettings that do not exceed 900 euros a year to the same landlord and those of a landlord who produces the tax office certificate for group 861 of the business activities tax⁹. With no withholding there is no withholding base, and the form is built entirely on that magnitude.

The unit is not the lease: it is the cadastral reference

Until 2014 form 180 identified the landlord and little else. Order HAP/1732/2014 replaced its annex VI, and since then every record describes the property: its location code, its twenty-character cadastral reference and its full address, normalised to the street-type codes of the Spanish National Statistics Institute³.

That change is what explains everything else, because a landlord can own several properties and a cadastral reference can only identify one. The tax office resolves the ambiguity with an example of its own that is worth reading in full, because it covers both cases:

A tenant of commercial premises and a parking space under one same lease, who also rents a second set of premises from the same landlord under a different lease⁴.

If the parking space shares the first premises' cadastral reference, the tenant includes at least two records: one with the single reference of the premises and the space together, and one with the reference of the second premises. In the first, the identifying details of the principal property go in, which here is the commercial premises. If the space has its own reference because it is an independent property, then it is three records.

The same logic applies in both awkward directions. If you rent only part of a property that has a single cadastral reference and there are other tenants of it, each tenant declares that reference, regardless of the property being the subject of other leases. And if the element let belongs to a block's owners' association and has no reference of its own, location code 4 goes in and the reference box is left blank.

How a single price is split between several properties

A lease says “3,000 euros a month for the premises and the warehouse” and the form asks for an amount per property. The tax office gives a cascade of three rules for that, in this order⁴:

The third rule is worth pausing on, because it is the only one of the three a reader would not have guessed. The tax office expressly authorises filing records with an empty amount box, provided they carry their cadastral reference. In other words: what the form is not prepared to lose is the identification of the property, not the split of the money. And that makes sense once you think what the form is for, which is to cross what a tenant declares having paid against what a landlord declares having received, property by property.

The four dates the rules print, and the only one that applies

This is the point at which almost every published guide gets it wrong, and not through carelessness: they get it wrong because they quote the norm.

The second sentence of article 108.2 extends the window from 1 to 31 January where the return is filed “on machine-readable media”¹. And paragraph fifteen of the form's own Order says electronic filing meets that requirement. Since article 12 of Order HAP/2194/2013 suppressed every channel other than the internet⁵, the exception is met every time and nobody can trigger the general rule.

The tax office confirms it from outside. Its own form 180 deadlines page publishes “from 1 January to 2 February 2026”⁶, which is that 31 January moved to the next working day by article 30.5 of Law 39/2015¹⁰, because 31 January 2026 fell on a Saturday. The taxpayer calendar files it under the same heading as forms 188, 190, 193, 194, 196 and 270⁷.

And the deadline leaves January twice running: 31 January 2027 is a Sunday, so the 2026 summary falls due on Monday 1 February 2027. Form 390 falls due that very same day, because its own 30 January 2027 is also a Saturday, and so does form 190. Three annual summaries of two different taxes collapsing onto one date.

Where a technical failure prevents online filing, article 17.2 of Order HAP/2194/2013 gives four further calendar days⁵, which the tax office also publishes on its deadlines page⁶. The form's own Order says nothing about technical failures, so there are no two norms to reconcile here.

It does reconcile with your four form 115s, and form 190 does not

The two annual withholding summaries fall due on the same day and behave in opposite ways.

Form 190 does not have to reconcile with its four form 111s, because article 2.1 of its Order reports the income paid “exempt income included”: its code L has thirty-two sub-codes of income nobody withheld from and which therefore never appeared on a quarterly return.

Form 180 has none of that. Its annex VI defines not a single income code, reserves no field for exempt income, and its only two magnitudes are called “withholding and payments on account base” and “withholding and payments on account”³: the base of the withholding and the withholding. A letting excluded from withholding has no withholding base and generates no record.

So form 180 does reconcile with its four form 115s, and there are only two legitimate differences, both provided for in annex VI itself:

• Repayments. Where a landlord returns during the year amounts they received in excess in earlier years, that amount is declared with the letter “N” in the sign field and is counted with a minus sign when totalling the summary's base. That is why the total base box of the type 1 record admits a negative sign while the withholding box is always shown unsigned: the two magnitudes can point in different directions.
• Back payments. Amounts paid whose accrual belongs to earlier years are declared in a separate record with the “accrual year” field filled in, and where one same landlord was paid amounts accruing in several years a record must be opened for each year.

There is a third asymmetry that does not change the totals but surprises anyone reviewing the file: the withholding percentage field says that where more than one percentage was applied during the year, only the last of them is stated³. On a record like that, the base multiplied by the percentage does not give the declared withholding, and that is correct.

The form counts records and the penalty counts people

The type 1 record has a box called “total number of recipients”, and annex VI defines it with a warning:

If one same recipient appears in several records, they are counted as many times as they appear³.

That box, in other words, counts records. The General Tax Act counts something else: “each item or set of items referring to one same person or entity”⁸. A tenant with one landlord and twelve premises declares twelve recipients and is exposed as a single person.

The comparison between the two middle rows is the most useful thing on this page. The cadastral reference and the location code are non-monetary items, and article 199.4 sets no maximum at all, so from the very first landlord getting it wrong costs more than not having filed at all: 200 euros against 150. The amounts, by contrast, go under article 199.5, with a scale of 0.5, 1, 1.5 or 2 per cent according to whether what was misdeclared exceeds 10, 25, 50 or 75 per cent of what should have been declared, and a fixed 500-euro penalty below 10 per cent⁸.

Two details almost no guide carries. Article 199.6 doubles the amount for a repeated offence and reaches only paragraphs 4 and 5, so the repeat offender who files nothing is not doubled and the one who gets it wrong is. And the 30% agreement reduction reaches neither of the two articles, because article 188.1 reserves it to articles 191 to 197: here only the 40% of article 188.3 for prompt payment without appeal applies.

Nor is there an article 27 surcharge for filing late, and the reason is structural: that surcharge is computed on the amount payable, and an information return has none.

A worked example with real numbers

A company rents three sets of premises of analogous characteristics from one landlord for 36,000 euros a year in total, without the lease saying which part belongs to each. All three have their own cadastral reference.

• Records: three, one per cadastral reference, even though the landlord is a single person and the lease a single one.
• Split: the properties being analogous, the second rule allows the total base to be split equally, so each record shows 12,000 euros.
• Recipients box: it will read 3. People declared: one.
• Deadline: the 2025 summary fell due on 2 February 2026, not on 31 January, because that day was a Saturday, and not on the 20 February its Order still prints.
• Had the cadastral reference of all three premises been wrong: article 199.4 charges 200 euros per affected landlord, and the landlord is one, so it is 200 euros. Not having filed the summary and putting it right voluntarily would have been 150.

That last pair of figures is the whole page in miniature: the form counts three records, the penalty counts one person, and the cheapest mistake to make is the one with no ceiling.

What the consolidated text still describes, and no longer exists

This deserves a warning, because anyone going to the norm will find a world that disappeared. The consolidated text of the 2000 Order still prints today an annual envelope to be sealed and deposited at a collaborating bank, an identifying label to be stuck on it, X.509.V3 certificates from the Spanish Royal Mint, DVD-R or DVD+R media with their density in BPI, the duty to file on media above 25 recipients and the exclusion of online filing above 1,000 records³.

None of that is in force, and the consolidated text carries not one note to warn you. The reason is technical and holds for any reading of the Spanish gazette: Order HAP/2194/2013 repealed all of it by blanket clause, not article by article, and a blanket repeal leaves no note in a consolidated text, because the consolidator can only annotate what a norm amends expressly.

The practical rule, then, is that a Spanish tax form needs two Orders: the form's own for what only it can say, and the general Order on information returns for the channel, because that one is updated every year.

What this summary does not cover

• The withholding itself. The 19% rate, reduced to 7.6% in Ceuta and Melilla, and the two different bases according to whether the landlord pays personal or corporate income tax belong to form 115⁹.
• Sub-letting that is investment income. Where the landlord is a personal income tax payer and the sub-letting income has that character, the payer files the specific form approved for it, which is form 123, and not this one.
• Rural lettings, which are not subject to this withholding and appear on no annual summary in this group.
• Whether a cadastral reference is valid. It is twenty characters with two check digits, and if you do not have it you can look it up on the Cadastre's electronic office from the property's address.