Annual IRPF Withholding Summary (Modelo 190) Spain

A Annual IRPF Withholding Summary (Modelo 190) Spain in Spain modelo 190 Spain is the official annual informative summary declaration through which employers, companies, professionals, and any other entities or individuals that made IRPF withholdings (retenciones a cuenta del IRPF) or payments on account (ingresos a cuenta) during the prior calendar year report the aggregate and per-recipient details of those withholdings to the Agencia Estatal de Administración Tributaria (AEAT), as required under Article 99 of Ley 35/2006 del Impuesto sobre la Renta de las Personas Físicas and Articles 70 through 108 of the Reglamento del IRPF (Real Decreto 439/2007, de 30 de marzo). Modelo 190 is the annual counterpart to the monthly or quarterly Modelo 111, which reports IRPF withholding payments made during the year — Modelo 190 consolidates the full year's withholding activity into a single recipient-level summary that the AEAT uses to pre-populate recipients' annual IRPF returns (borradores de declaración) in Renta Web.

The obligation to file Modelo 190 falls on every withholding agent (retenedor) that made IRPF withholdings during the prior year on any of the following income types: employment income (rendimientos del trabajo) paid to employees and directors; professional fees (rendimientos de actividades profesionales) paid to autónomos subject to the standard 15% professional withholding rate (or the 7% reduced rate for newly registered professionals in their first three years); agricultural and forestry activity income (rendimientos de actividades agrícolas, ganaderas y forestales) subject to withholding; prizes and lottery winnings subject to withholding (premios); income from rental of moveable property (arrendamiento de bienes muebles); income from intellectual and industrial property rights (derechos de imagen, propiedad intelectual); and management fees paid to administrators and members of boards of directors (retribuciones a administradores y consejeros) subject to 35% or 19% withholding depending on the company's turnover under Article 101.2 LIRPF.

Modelo 190 is a recipient-level declaration — unlike Modelo 111 which reports aggregate quarterly withholding totals, Modelo 190 requires a separate record for each individual person or entity from whom withholdings were made during the year. Each record must specify: the recipient's NIF, name, the income type code (clave and subclave from the official classification table published in the Orden ministerial governing Modelo 190), the gross income paid, the IRPF withholding percentage applied, the total withholding amount deducted, and, for employment income, additional personal circumstances data (personal data code — situación familiar, number of children and dependants) that the AEAT uses to verify the correctness of the withholding rate applied.

The annual filing deadline for Modelo 190 is January 31 of the year following the reporting year. For the 2024 calendar year, Modelo 190 must be filed by January 31, 2025. Electronic filing through the AEAT Sede Electrónica using a certificado digital, Cl@ve PIN, or the official AEAT file import system is mandatory for all filers — both companies and individuals — under Orden HAP/2194/2013. Large volume declarers (those with more than a certain number of recipients) must file using the AEAT's official XML-format electronic file through the Sede Electrónica data import system.

The information reported in Modelo 190 is used by the AEAT in three primary ways. First, it pre-populates the borrador de declaración de la renta (pre-filled tax return draft) made available to taxpayers each April in Renta Web — making Modelo 190 a critical compliance document for employees and professionals who rely on their employer's or payer's withholding data being correctly reported. Second, the AEAT uses Modelo 190 data to cross-check the Modelo 111 payments made during the year — if the annual Modelo 190 total withholding amount differs materially from the sum of Modelo 111 payments, the AEAT initiates a comprobación de datos procedure under Article 131 LGT. Third, the AEAT uses Modelo 190 data in its IRPF audit risk-scoring system to flag recipients who did not file their annual IRPF return despite having withholdings reported on their behalf.

For employers, correctly preparing Modelo 190 requires maintaining accurate payroll records throughout the year — including tracking changes in employees' personal circumstances (marital status, new dependants, disability status) that affect the applicable withholding rate under the IRPF withholding tables published by the AEAT. Employees must communicate changes in their personal circumstances to their employer via Modelo 145 (Comunicación de datos del perceptor de rendimientos del trabajo a su pagador) under Article 88 of the Reglamento del IRPF — failure to do so may result in under-withholding that must be regularised in the employee's annual Modelo 100.

Modelo 190 must be filed annually by every employer, company, self-employed professional, public administration, and any other natural or legal person that acted as a withholding agent (retenedor) during the prior calendar year — meaning they paid income subject to IRPF withholding under Articles 75–107 of the Reglamento del IRPF (RD 439/2007) and deducted those withholdings from payments made to recipients.

Modelo 190 is required for any employer who paid salaries to employees during the year and applied monthly IRPF withholding — even if the employee's annual salary was below the IRPF minimum threshold and the withholding rate was 0%. Zero-withholding employees must still be reported in Modelo 190 if they were issued Modelo 145 personal circumstances data that the employer applied to determine the withholding rate.

The declaration is needed for companies, public administrations, foundations, and cooperatives that paid professional service fees to autónomos with IRPF withholding applied — for example, payments to freelance accountants, architects, lawyers, engineers, or marketing professionals subject to the 15% professional withholding rate or the reduced 7% rate for newly registered professionals.

Modelo 190 is required when a company paid board member fees (retribuciones a administradores y consejeros de sociedades) subject to 35% withholding for companies with turnover above €100,000, or 19% for smaller companies, under Article 101.2 of Ley 35/2006 LIRPF. Both managing directors (administradores únicos and administradores solidarios) and non-executive board members (consejeros) receiving remuneration must be individually reported.

The annual summary is also required when a company paid agricultural, livestock, or forestry activity income subject to withholding — for example, payments to agricultural producers under a supply contract where withholding is applied at rates specified in Article 95 of the Reglamento del IRPF.

Modelo 190 must be filed even for a year in which no Modelo 111 quarterly payments were made — if withholdings were applied during the year but all resulted in zero or refunded amounts, a nil Modelo 190 is still required. Conversely, if a company made no payments of any income type subject to withholding during the year (for example, a dormant company with no employees and no supplier professional fees), no Modelo 190 filing obligation exists for that year.

The filing deadline is January 31 of the following year without exception. Employers who failed to file Modelo 111 quarterly during the year may not defer Modelo 190 — both the outstanding Modelo 111 filings and the Modelo 190 annual summary are separately required, and each generates its own late-filing penalty exposure under Articles 191–199 of Ley 58/2003 LGT.

Under Spanish law, the Constitución Española 1978 is the supreme law. The Código Civil governs contractual obligations under Article 1255 (libertad de pactos). The AEAT administers taxation. The Juzgados de Primera Instancia have general civil jurisdiction. The Ley 39/2015 governs administrative procedure. The LOPDGDD (LO 3/2018) and RGPD govern data protection through the Agencia Española de Protección de Datos (AEPD).

Modelo 190 Spain under Ley 35/2006 del IRPF Article 99 and RD 439/2007 requires the following key elements for a complete and AEAT-compliant annual withholding summary declaration.

Declarant (Withholding Agent) Identification: The NIF and full legal name of the entity or person who made the withholdings (retenedor), their fiscal address, and the name and NIF of the authorised representative signing the declaration. For employers who are legal entities (sociedades), the company's NIF and the name of the legal representative (administrador or apoderado) are required.

Summary Totals: Aggregate totals for the full declaration — the total number of recipient records (número de perceptores), total gross income paid across all recipients (importe total de percepciones), and total IRPF withholdings applied across all recipients (importe total de retenciones e ingresos a cuenta). These summary figures must match the sum of all individual recipient records and must reconcile with the total Modelo 111 payments made during the year.

Per-Recipient Records: For each recipient, the declaration must include: (1) recipient NIF; (2) recipient full name and first surname; (3) income type code (clave de percepción) from the official classification table — key codes include A (employment income), B (directors/administrators), C (unemployment benefits), D (passive income from public entities), E (other employment-related income), F (professional activity income); (4) subclave indicating specific circumstances; (5) gross income paid (dinerarias — cash payments); (6) income paid in kind (en especie — non-cash benefits); (7) total withholding amount; (8) withholding percentage applied; (9) reductions applied to the taxable base (where applicable).

Employee Personal Circumstances Data (Clave A Records): For employment income records (clave A — rendimientos del trabajo), Modelo 190 requires additional fields: the employee's personal situation code (situación familiar — 1, 2, or 3 corresponding to: single with descendants or disabled persons, married with non-earning spouse, or other situation) as declared by the employee in Modelo 145; the number of children and other dependants under Article 58 and 59 LIRPF declared by the employee; disability degree (grado de discapacidad); and whether the employee applied the reducción por movilidad geográfica (geographical mobility deduction under Article 20 LIRPF).

Professional Fees Records (Clave G): Payments of professional activity income (rendimientos de actividades profesionales) are reported under clave G. For each autónomo recipient, the declaration must include the gross fee paid, the withholding rate applied (15% standard, 7% for newly registered professionals in their first three years under Article 95.1 Reglamento IRPF), and the total withholding amount. The withholding rate must match the invoices issued by the professional — discrepancies trigger AEAT automatic verification.

Management Fees (Clave B): Board member and director remuneration is reported under clave B. Two subclauses apply: B.01 for directors of companies with prior-year turnover above €100,000 (35% withholding rate) and B.02 for directors of smaller companies (19% withholding rate). Newly incorporated companies without a prior-year turnover use B.02 until their first full year turnover exceeds the threshold.

In-Kind Benefits (Retribuciones en Especie): Employer-provided benefits valued as IRPF-taxable income — company cars (use of a vehicle), housing allowances, health insurance premiums above the €500 annual exempt limit per person, meal vouchers above the daily exempt limit, and stock options — must be separately reported with the income-in-kind value (valoración en especie) and the ingreso a cuenta (deemed withholding on the in-kind benefit) applied by the employer. The AEAT's official valuation rules for common in-kind benefits are published in Articles 43–48 of the LIRPF and Articles 44–48 of the Reglamento IRPF.

Reconciliation with Modelo 111: The total withholding amounts reported in Modelo 190 must reconcile with the sum of Q1, Q2, Q3, and Q4 Modelo 111 payments made during the year. A material discrepancy triggers a AEAT comprobación de datos request for explanation. Common sources of discrepancy include end-of-year regularisation of withholding rates (recálculo de tipo de retención), payroll year-end bonus payments straddling quarters, and late inclusion of new employees.

Forms-legal.com provides this Modelo 190 Spain template as a practical reference for employers and withholding agents. Preparing Modelo 190 accurately requires complete payroll records and professional software — gestoría laboral or asesor fiscal support is strongly recommended to confirm recipient-level data accuracy and AEAT format compliance under the current Orden ministerial governing Modelo 190.

Under Spanish law, the Constitución Española 1978 is the supreme law. The Código Civil governs contractual obligations under Article 1255 (libertad de pactos). The AEAT administers taxation. The Juzgados de Primera Instancia have general civil jurisdiction. The Ley 39/2015 governs administrative procedure. The LOPDGDD (LO 3/2018) and RGPD govern data protection through the Agencia Española de Protección de Datos (AEPD).