Modelo 347 — Third-Party Transaction Report Spain

Modelo 347 — Third-Party Transaction Report Spain is the annual informative tax declaration (declaración informativa anual de operaciones con terceras personas) required under Real Decreto 1065/2007, art. 31, by which businesses, professionals, and entities established or resident in Spain must report to the Agencia Estatal de Administración Tributaria (AEAT) all transactions carried out with any single third party whose aggregate annual value equals or exceeds €3,005.06, including VAT (IVA). The obligation arises from the Reglamento General de las actuaciones y los procedimientos de gestión e inspección tributaria (RGAT), approved by Real Decreto 1065/2007, which replaced and expanded the earlier reporting framework of the derogated Reglamento General de la Inspección de los Tributos.

Modelo 347 is a purely informative declaration — it does not trigger a tax payment. Its purpose is to enable the AEAT to cross-check data reported by two parties to the same transaction: if both the buyer and the seller are obliged to file Modelo 347, the AEAT matches the figures declared by each and flags discrepancies that may indicate unreported income, VAT fraud, or incorrect invoicing. The threshold of €3,005.06 applies to the sum of all operations with a single counterparty throughout the calendar year, computed separately for deliveries (entregas) and acquisitions (adquisiciones). The AEAT's Sistema de Información Inmediata (SII) does not exempt obliged parties from Modelo 347 unless they are already reporting under the SII real-time regime (Real Decreto 596/2016).

The categories of operations that must be reported in Modelo 347 include: supplies of goods and services subject to IVA; leasing transactions involving real property (arrendamientos de bienes inmuebles); insurance operations; banking and financial operations; grants, subsidies, and aid received from public administrations exceeding the threshold; and advance payments (pagos anticipados) received or made. Imports and exports reported separately through customs declarations are excluded. Intra-Community deliveries and acquisitions reported through Modelo 349 are also excluded from Modelo 347 to avoid duplication.

The filing deadline for Modelo 347 is February of the year following the calendar year being reported — for example, operations during calendar year 2024 must be filed during February 2025. The declaration is filed electronically through the AEAT's electronic seat (Sede Electrónica) at sede.agenciatributaria.gob.es using a certificado digital, DNIe, or Cl@ve PIN. Paper filing is not permitted for entities required to file electronically.

Modelo 347 requires detailed identification of each counterparty: NIF (Número de Identificación Fiscal) or, for non-Spanish counterparties, the foreign tax identification number; full legal name or business name; registered address; and the total amount of operations during the period, broken down by quarter if the total exceeds the threshold. For real property leasing transactions, the cadastral reference (referencia catastral) of each property and the nature of the operation (lessor or lessee) must also be declared.

The Ley General Tributaria (Ley 58/2003), Article 93, establishes the general obligation of third parties to provide information to the AEAT — the foundation upon which Modelo 347 is built. Failure to file, late filing, or material errors in Modelo 347 constitute tax infractions under the LGT Articles 198 and 199, with sanctions ranging from fixed fines of €200 (for late filing without prior AEAT request) to proportional penalties of 0.5% to 2% of the undeclared or incorrectly declared amount, with minimum and maximum limits. Voluntary late filing before AEAT request incurs a reduced fixed sanction of €100 under Article 198.2 LGT.

Modelo 347 — Third-Party Transaction Report Spain must be filed by any person, entity, or professional establishment subject to Spanish tax jurisdiction that has carried out operations with a single counterparty whose total annual value equals or exceeds €3,005.06 including VAT, during the preceding calendar year. The AEAT considers both purchases and sales separately — if you purchased more than €3,005.06 from a supplier, that supplier must be reported regardless of whether sales to them also exceeded the threshold.

Modelo 347 is required for sociedades limitadas (S.L.), sociedades anónimas (S.A.), cooperativas, fundaciones, and other legal entities engaged in commercial or professional activities in Spain. Autónomos (self-employed professionals and sole traders) registered with the AEAT and operating above the threshold are equally obliged. Public administrations, universities, and non-profit organisations are also obliged to report grants and subsidies paid to recipients who exceed the threshold.

Modelo 347 is required when a Spanish company leases commercial or residential property, since the lessor must report the lessee's identity and the total lease payments received. Real estate agencies (agencias inmobiliarias) must report each landlord for whom they manage properties where annual rents exceed the threshold. Insurance companies must report policyholders whose aggregate premiums exceed the limit.

Modelo 347 is not required when the declarant is enrolled in the SII (Suministro Inmediato de Información) regime under Real Decreto 596/2016 — large businesses (grandes empresas with turnover exceeding €6 million), VAT groups, and voluntary SII participants are exempted from Modelo 347 since their invoicing data is already reported in real time to the AEAT. Similarly, operations already declared through Modelo 180 (withholding tax on rentals), Modelo 182 (donations to non-profits), or Modelo 190 (payroll withholding) need not be duplicated in Modelo 347.

Modelo 347 must be filed during February each year. The form is submitted through the AEAT Sede Electrónica. Prior to filing, businesses should reconcile their supplier and customer ledgers against the third-party transaction totals to identify all counterparties meeting the threshold, particularly for year-end reconciliation processes managed through the empresa's software de contabilidad (accounting software) certified under the Plan General Contable.

Banking and financial institutions (entidades de crédito) must declare interest paid on deposits, fees charged, and loan repayments received from clients whose total annual operations exceed €3,005.06. Telephone and utility companies (compañías de telecomunicaciones) must also declare amounts billed to business customers above the threshold. Professional associations (colegios profesionales) and chambers of commerce (cámaras de comercio) reporting member fees are similarly obliged under Real Decreto 1065/2007 art. 31.4.

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).

A correctly prepared Modelo 347 — Third-Party Transaction Report Spain under Real Decreto 1065/2007 art. 31 must include the following mandatory data elements and declarations.

Declarant Identification: Full legal name or business name of the declarant, NIF (Número de Identificación Fiscal) issued by the Agencia Tributaria, and the fiscal year (ejercicio) being reported. The declarant's representative (representante legal or apoderado) must also be identified if filing on behalf of a legal entity.

Third-Party Records: For each counterparty whose aggregate annual transactions reach or exceed €3,005.06, Modelo 347 requires: (1) NIF or foreign tax identification number; (2) full legal or personal name; (3) complete registered or habitual address; (4) the total operations amount for deliveries (entregas) and acquisitions (adquisiciones) separately; (5) quarterly breakdown if required for real property transactions; (6) indication of whether amounts include VAT charged on the transactions.

Real Property Operations: For leasing and real property transactions, the cadastral reference (referencia catastral) obtained from the Dirección General del Catastro must be included, along with a flag indicating whether the declarant acted as lessor (arrendador) or lessee (arrendatario), the CNAE code of the property use, and the autonomous community (comunidad autónoma) where the property is located.

Public Grants and Subsidies: Public administrations and grant-awarding bodies (organismos públicos) reporting grants and subsidies must identify each recipient's NIF, the granting body's code, the programme name, the total amount granted, and whether the amounts are subject to withholding tax (retención).

Cash Operations: Real Decreto 1065/2007 art. 33 imposes a special reporting obligation for cash receipts (operaciones en metálico) exceeding €6,000 during the year from a single counterparty — these must be identified separately in Modelo 347 with the total cash amount.

Insurance Operations: Insurance companies (entidades aseguradoras) must report each policyholder whose annual premium payments exceed the threshold, including the type of insurance (life, health, property, liability), the policy reference, and the premium amount.

Corrections and Amendments: Modelo 347 may be amended by filing a complementary or substitutive declaration (declaración complementaria o sustitutiva). A complementaria adds records omitted from the original; a sustitutiva replaces the original declaration in its entirety. Both must reference the original filing number (número de justificante) assigned by the AEAT upon original submission.

Forms-legal.com provides this Modelo 347 template as a preparation aid. Filing Modelo 347 involves specific AEAT-validated data formats — companies should use AEAT-certified accounting software or consult a gestor administrativo or asesor fiscal to validate all NIF numbers through the AEAT's Censo de Empresarios portal before submission.

Banking Operations Reporting: Credit institutions (entidades de crédito) registered with the Banco de España must report in Modelo 347 all interest paid to business depositors, commissions and fees charged, and loan repayments received from business clients whose annual totals exceed the €3,005.06 threshold. The Banco de España's Circular 1/2013 on information obligations complements the Modelo 347 reporting framework for the financial sector.

Pre-Filing Reconciliation: Before submitting Modelo 347, declarants must reconcile their Libro Registro de Facturas Emitidas (issued invoices register) and Libro Registro de Facturas Recibidas (received invoices register) — both mandatory under Real Decreto 1619/2012 (Reglamento de Facturación) — against the third-party totals calculated for the declaration. Any discrepancies between accounting records and invoice registers must be resolved before filing to avoid AEAT cross-check sanctions under LGT art. 199.

Under the Ley General Tributaria (Ley 58/2003) art. 93, the obligation to provide information to the AEAT is enforceable. Real Decreto 1065/2007 governs the mechanics of the declaration. The AEAT's Sede Electrónica (sede.agenciatributaria.gob.es) is the exclusive filing channel. Sanctions for incorrect or late filing fall under LGT art. 198 and 199. The Tribunal Económico-Administrativo Central (TEAC) hears administrative appeals against AEAT sanctions before judicial review.

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).