What Spanish form 347 is and who has to file it

Form 347 is the only return in the whole Spanish tax envelope with which nothing is paid. It computes no liability, nothing is remitted, nothing is refunded, and there is no way for it to come out at zero or negative in the sense a self-assessment does. It is a list: every person and entity you did more than €3,005.06 of business with during a calendar year.

That list exists because your customer files another one. The Spanish tax agency receives both and compares them, and that is where most of the "discrepancy" letters that arrive in spring come from. So the useful question here is not how much, but three separate things: whether you have to file it, who has to appear, and what to do when your figure and the other side's do not fit together.

The first thing to check is whether you are excluded

This is the part almost every guide leaves for the end, and it is the part that settles the case for most taxpayers. Article 32 of the Regulation takes five groups out of form 347:

The first row is today the largest and the least discussed. Article 62.6 of the VAT Regulation requires the registers to be kept through the tax agency portal by anyone whose settlement period is monthly under article 71.3 of that same Regulation, and that reference is to the whole article: all four of its numbers, including the third, which is the monthly-refund register. If your invoices already reach the tax agency one by one and within four days, there is nothing left to summarise in February. The tax agency says so without hedging in its FAQ: taxpayers in the monthly-refund register have not been required to file form 347 since 2017.

That is worth pausing on, because it is the exact opposite of what happens in another form in the same block. Article 108.1 of the income-tax Regulation, which decides whether form 111 is filed monthly or quarterly, refers to numbers 1 and 2 of article 71.3 and to no others. A company in the monthly-refund register is therefore in the following position: it files form 303 monthly, it files form 111 quarterly and it does not file form 347 at all. All three results come out of the same article 71.3 and differ because each rule cites it differently. When one Spanish rule refers to numbered paragraphs of another, you have to read which numbers. And since 2023 that same article 62.6 has a fourth consequence: article 3.3 of Royal Decree 1007/2023 excludes from the invoicing-software regulation anyone keeping their registers under its terms, so that same company also falls outside Verifactu.

The €3,005.06 does not work the way almost everyone thinks

Article 33.1 requires you to list the persons with whom you carried out operations that "taken together for each of those persons or entities exceeded the figure of €3,005.06 during the corresponding calendar year". And it immediately adds the sentence that changes everything: the information is supplied broken down by quarter and, for those purposes, "supplies and acquisitions of goods and services shall be computed separately".

The annex to the Order confirms it from the other side, because each operation key carries its own threshold written into the definition:

Two consequences follow, and a summary of the "€3,005.06 with that customer" kind makes both impossible to see.

The first: if you sell one customer €2,000 and buy another €2,000 from them, you have done €4,000 of business with them and you do not report it, because neither key reaches the threshold on its own. The second is the mirror image: if you sell them €10,000 and buy €20,000, that customer appears twice in your return, once per key. And that is not a figure of speech. The tax agency's completion instructions say of the summary that the total number of persons and entities listed is the sum of all those listed under keys A to G and that "if the same reported party appears in several records, it shall be counted as many times as it is listed".

Nor is it a quarterly limit. Four quarters of €800 are €3,200 for the year and are reported, even though no single quarter comes close to the figure.

The amount includes VAT, which is why it never matches form 303

Article 34.2.a) reports "the total amount of the consideration, including the VAT charged or borne". That is a substantive difference from form 303 and from form 390, which work with taxable bases.

An invoice of €1,000 plus €210 of VAT contributes €1,210 to form 347 and €1,000 to the form 303 base. The totals of the two forms therefore never match, and chasing a match is chasing a reconciliation the rules do not ask for. Article 34.2.b) adds one more case: under the special agriculture, livestock and fisheries regime you report the total consideration plus the compensation received or paid.

A year of nothing but refunds can be reportable

Article 34.4 requires the total amount to be reported "net of the returns, discounts and rebates granted and of the operations voided in the same calendar year", also taking into account price alterations and taxable-base adjustments for the customer's insolvency under article 80.tres of the VAT Act. And what is compared against €3,005.06 is the absolute value of that result.

The tax agency settles this with two of its own worked examples, and both run against intuition.

In the first, an entity sells €4,000 in January and, six months later, having not been paid, adjusts the taxable base in the fourth quarter. The annual amount is zero, so it does not file form 347 for that counterparty: in absolute value it does not reach the threshold, even though a €4,000 invoice was issued during the year.

In the second, an entity sells €20,000 in December of one year and in the first quarter of the next receives a €4,000 return of goods. The first year it reports key B, annual amount €20,000, all in the fourth quarter. The second year it reports key B, annual amount minus €4,000, all in the first quarter, even though there was no sale at all that year. The file design has an alphabetic sign field, filled with an "N" when the annual amount is below zero, precisely for this.

The breakdown is quarterly, except in three cases

Since the 2014 return the information is supplied broken down by quarter. There are three exceptions, all in article 33.1 and in 34.1.h):

• Cash receipts above €6,000 from one and the same person. They go in their own field and always as an annual figure. And article 35.5 adds a little-known detail: if that money is received after the return has been filed, or if at that moment it had not yet reached €6,000, it is reported separately in the following year's return.
• The special cash-basis regime, both for whoever applies it and for whoever is the recipient of operations under it. Here the operation is additionally reported twice: once on the general accrual rule of article 75 of the VAT Act and once on the accrual of article 163 terdecies. In the tax agency's own example, a supplier who invoices €4,000 in 2014 and collects €2,500 that year reports an annual amount of €4,000 and a cash-basis accrued amount of €2,500; the following year it reports an annual amount of zero and a cash-basis accrued amount of €1,500.
• Communities of owners and social-purpose entities, which supply all their information on an annual basis.

Those last two categories also have exclusions of their own, in paragraphs 5 and 6 of article 33: a community of owners does not report supplies of water, electricity or fuel of any kind intended for communal use and consumption, nor insurance covering property and rights relating to communal areas and elements. The tax agency's example puts numbers on it: a community that spends €20,000 on works in communal areas and €40,000 on fuel reports key D for €20,000 and does not report the €40,000.

Why your figure and your supplier's can differ and both be right

This is the highest-intent question on the whole subject, and it deserves its own section because the answer is not in the threshold article but in two different rules read together.

Article 35.1 does not allocate the operation by invoice date or by payment date. It allocates it to the period in which, "in accordance with article 69 of the VAT Regulation, the invoice must be recorded in the register".

And that article 69 sets two different clocks:

• Issued invoices (paragraph 1): they must be entered by the time the tax on those operations is settled and paid or, in any case, before the legal deadline for doing so voluntarily expires.
• Received invoices (paragraph 3): they "shall be recorded in the corresponding register in the order in which they are received, and within the settlement period in which the deduction is to be taken".

The issuer goes by their own accrual; the recipient by when the invoice arrives and when the VAT is deducted. The tax agency illustrates it with names and figures: company X sells to Y for €10,000 on 20 March, Y receives the invoice on 30 April and records it that day. In X's form 347 the operation goes under key B in the first quarter; in Y's, under key A in the second. Both returns are correct and they do not match.

The practical consequence is that, faced with a difference, the first thing to check is whether it is only which quarter. If the annual amount matches and only the split between quarters moves, there is nothing to rectify. If what does not match is the annual amount, then it is worth reviewing, and there it matters to distinguish the two correction routes, which the tax agency's instructions separate precisely:

• Supplementary return, for the inclusion of data: for operations that, having had to be included in another return for the same year, were completely omitted. The two returns coexist.
• Replacement return: annuls and completely replaces an earlier return in which inexact or wrong data was included.

In both cases you must state the thirteen-digit identifying number of the earlier return. Using the supplementary box to correct a wrong figure does not correct it: it leaves it inside and adds another.

The operations that stay out

Article 33.2 excludes nine categories from the duty to report, and they are worth keeping in mind because the form is completed from the accounts and the accounts do not separate them:

1. Operations for which no invoice had to be issued, or in which the recipient's details did not have to be stated.
2. Operations carried out outside the business or professional activity.
3. Free supplies or acquisitions not subject to or exempt from VAT.
4. Lettings of goods exempt from VAT made by individuals or entities without legal personality outside any other activity.
5. Acquisitions of stamped documents and postal franking, except those that are collectors' items.
6. The exempt operations of the own sector of social-purpose entities under article 20.tres of the VAT Act.
7. Imports and exports of goods, and anything carried out directly from or for a permanent establishment located outside Spain.
8. Shipments between the mainland or the Balearics and the Canaries, Ceuta and Melilla.
9. Generally, anything subject to a periodic duty to supply information to the State tax administration that has already been included in a different specific return with coincident content.

The ninth is what prevents duplication with the other informative returns, and it is also why withholdings already reported on form 180 or form 190 are not repeated here.

What is reported separately inside the same record

Article 34.1 requires six things to be stated "separately from other operations carried out between the same parties". The two that come up most in practice:

• The letting of business premises (letter d). It is flagged with an "X" and, in addition, the landlord completes a separate property record with the cadastral reference and the details needed to locate the property. The annex is explicit that this record is completed "irrespective of whether the amount has already been included under key B", so the same rent appears in two places on purpose. If you need to find the cadastral reference of the premises, it is on the property tax bill and in the deed.
• Property transfers subject to VAT (letter i). They go in their own quarterly and annual boxes, but inside the same record and forming part of the total amount: they are not added on top of it. What does come out of the annual total is insurers' insurance operations and lettings, which go in separate records.

The other four are insurers' insurance operations, travel agencies' intermediation, amounts collected on behalf of third parties and reverse-charge operations under article 84.Uno.2 of the VAT Act, plus operations exempt under the non-customs warehousing regime.

When it is really due

Article 10 of the Order says the return shall be filed "during the month of February each year in relation to the operations carried out during the previous calendar year". That is where the "up to 28 February" repeated by almost every page about this form comes from, and this year it is wrong.

When the last day of a deadline is a non-working day, article 30.5 of Act 39/2015 pushes it to the next working day, and paragraph 2 of that same article declares Saturdays, Sundays and public holidays to be non-working. 28 February 2026 is a Saturday. The 2025 return is therefore due on Monday 2 March 2026, and that is how it appears in the taxpayer calendar published by the tax agency itself, where form 347 for the year 2025 sits under the heading "Up to 2 March" and not in February. Which days drop out of that count, and how it differs from a court deadline or a contractual one, is set out in Spanish working days explained.

It is not a rare case. 28 February 2027 is a Sunday, so the 2026 return will be due on 1 March 2027. The next one without an extension will be the 2027 return, because 29 February 2028 falls on a Tuesday. And no national holiday can disturb this count: the fixed state calendar has nothing between 6 January and Good Friday, which never falls before 20 March.

Article 10 also refers to article 17.2 of Order HAP/2194/2013, and that is the only extension this form has: where technical reasons make internet filing within the deadline impossible, filing may take place "during the four natural days following the end of that deadline". It is conditional on that failure, so it is not a general extension, but it is worth knowing because since 2022 there is no other route: article 1 approves the form "in electronic format" and articles 3 to 9, which governed the printed form and computer-readable media, are suppressed.

The only thing that costs money is getting it wrong

Since nothing is paid, filing late generates no surcharge. It generates a penalty, and the arithmetic sits in two articles of the General Tax Act.

Three details in that table get lost in any summary. First: article 198.2 halves the penalty and both limits too, so the minimum drops from €300 to €150. Second: the increase for repeated commission in article 199.6 refers to paragraphs 4 and 5 of that article and does not reach article 198, so a repeat offender who simply does not file does not see their penalty doubled. And third: when the amount reported incorrectly is exactly 10 % of what should have been reported, the article 199.5 scale says nothing, because one paragraph speaks of a percentage "above 10" and the next of one "below 10 per cent". At that point the general rule of the first paragraph governs, "up to 2 per cent … with a minimum of €500", and the €500 is the operative figure.

A worked example with real numbers

A firm with one large customer and one large supplier, for the 2025 year.

It invoices the customer €6,050 including VAT each quarter: €24,200 for the year. That passes €3,005.06, so they go in under key B for €24,200, with €6,050 in each of the four quarters.

It buys services from that same customer for €1,210 including VAT each quarter: €4,840 for the year. That also passes the threshold, so they go in again under key A for €4,840. In the summary that counterparty counts as two related persons, not one, and contributes €29,040 to the total annual amount.

The firm also lets the customer an office. That letting is flagged with an "X" and reported again in a separate property record with the cadastral reference, even though its amount already sits inside key B: the total number of properties listed goes up by one.

And the customer paid €7,000 in cash over the course of the year. That passes €6,000, so it goes in its own field, as an annual figure and not by quarter.

The return is filed up to 2 March 2026. If the firm did not file it and had twelve counterparties that should have appeared, article 198.1 would give 12 × €20 = €240, raised to the €300 minimum. Filing late on its own initiative would give €120, raised to the €150 minimum. And filing on time but omitting €400,000 of the €900,000 that should have been reported would make those €400,000 44.4 % of the total, so article 199.5 would apply 1 %: €4,000.

What is new in this year's form

Order HAC/1431/2025 of 3 December, published in the Official State Gazette of 12 December, created a new field in the reported-party record: "BDNS call number", at positions 300 to 305. It identifies, in the National Subsidy Database, the call for the subsidies and aid granted by public administrations that are reported under key E, and it can only be completed when the operation key is that one.

Its final provision makes it applicable for the first time to the filing of form 347 for 2025 and subsequent years, that is the return filed in early 2026. It mainly affects public bodies as filers, but it is the kind of change a page written a year ago cannot capture.

How it fits with the other forms

Form 347 closes the year on a set of obligations we cover separately. Form 303 settles each quarter's VAT and works with taxable bases; form 130 pays income tax on account for the self-employed person themselves; form 111 remits the income tax withheld from employees and professionals, and form 115 the tax withheld from the landlord of business premises. None of them identifies the counterparties by tax number with an annual amount, and that is what this one does.

If what you want is to check your own case, the form 347 calculator applies the thresholds by key and in absolute value, works out the quarterly breakdown, computes the due date for whichever year you choose and puts a price on the articles 198 and 199 penalty.