Modelo 347 — Annual VAT Operations Declaration for Expat Businesses in Spain

Modelo 347 — The Essentials at a Glance

Modelo 347 is Spain's annual informational declaration of operations with third parties. It is filed each February by autónomos, companies, professionals and entities carrying out economic activity in Spain, and it lists every customer and supplier with whom the aggregate of operations during the previous calendar year exceeded €3,005.06 (VAT included). The form does not generate tax in itself — it is a cross-check the Agencia Tributaria uses to match invoices declared by both sides of each commercial relationship.

The legal basis sits in Real Decreto 1065/2007 (the Reglamento General de Gestión e Inspección Tributaria), and the official Agencia Tributaria page is at sede.agenciatributaria.gob.es. The six cards below cover the essentials; the rest of the guide takes each in detail.

What Is Modelo 347?

Modelo 347 — Declaración anual de operaciones con terceras personas — is an annual information return. It does not calculate or collect VAT, IRPF or any other tax. It is a reconciliation device: a list of who you traded with, how much, and in which quarter, that the Agencia Tributaria runs against the equivalent list filed by every other Spanish business. Mismatches generate computer-generated enquiry letters known as paralelas.

The obligation has existed in essentially its current form since 2008. Its legal basis is in Articles 31–35 of Real Decreto 1065/2007. The current filing form, periodicity and threshold are confirmed each year by ministerial order. Filing is electronic only — there is no paper option, and walk-in filing was discontinued years ago. The official AEAT landing page is at sede.agenciatributaria.gob.es.

Who Must File Modelo 347?

The obligation is broad. In practice, almost every autónomo and small company in Spain ends up filing Modelo 347 in at least some years. Three conditions must be met.

1. You must carry out economic or professional activity in Spain. This includes individual autónomos, professionals (abogados, arquitectos, médicos, consultants), companies of all sizes, civil partnerships (comunidades de bienes), associations, foundations and non-profit entities to the extent they carry out economic activity. Public bodies and entities with VAT-exempt activities can also be in scope for their commercial operations.

2. You must have had operations with at least one counterparty over €3,005.06 in the calendar year (VAT included). The threshold is per counterparty per year — not per invoice, not per quarter, and not in aggregate across all clients. Add up every invoice issued to one client or received from one supplier across all four quarters.

3. You must not fall into an exempt category. The main exemptions — modulos, REAGP, equivalence surcharge, and SII users — are explained below.

The €3,005.06 Threshold and What Counts

The €3,005.06 number traces back to the old peseta law (500,000 pesetas) and has been kept ever since. It is applied per counterparty, per calendar year, with VAT included.

What you include in the aggregate:

• All invoices issued to (or received from) the same NIF/CIF in the calendar year.
• The full invoice value, with VAT (or recargo de equivalencia) added.
• Advance payments and instalments — recorded in the quarter received or paid.
• Rebates, returns and credit notes — as negatives in the quarter applied.

What you exclude:

• Operations already reported on Modelo 349 (intra-EU acquisitions and supplies).
• Imports and exports cleared through customs and reported elsewhere.
• Operations with permanent establishments outside Spain.
• Operations subject to withholding (retenciones) declared on Modelo 190 — the wages paid to employees, for example.
• Insurance premiums and indemnities — these have their own reporting framework.

Who Is Exempt — Modulos, REAGP, Equivalence Surcharge and SII

Several groups are released from the obligation. The most important for expat autónomos is the modulos exemption.

Autónomos Under Modulos (Estimación Objetiva)

Autónomos taxed under the Régimen de Estimación Objetiva — known universally as modulos — are exempt from filing Modelo 347 for the activities covered by that regime. Modulos applies to a closed list of activities (small bars and restaurants, taxis, small shops, certain trades) that pay a fixed IRPF and VAT amount based on indicators like square metres, staff numbers and electricity use rather than actual income. Because the Agencia Tributaria does not need invoice-level data to assess these businesses, the cross-check serves no purpose.

Special VAT Regimes — REAGP and Equivalence Surcharge

Two further VAT special regimes are exempt: the Régimen Especial de la Agricultura, Ganadería y Pesca (REAGP), used by farmers and fishermen, and the recargo de equivalencia, used by retailers selling to final consumers. As with modulos, the exemption only covers operations within those regimes — if you have any activity outside them, that part is reported.

Businesses on SII

Businesses required to use the Suministro Inmediato de Información (SII) — large companies (over €6m turnover), VAT groups, and monthly VAT refund applicants — already submit invoice-level data to the Agencia Tributaria within four days of issue. They are therefore exempt from Modelo 347. Most autónomos are not on SII and continue to file annually.

The Filing Window — February Each Year

Modelo 347 is filed in February each year, reporting all qualifying operations from the previous calendar year. The deadline has been settled at 28 February (29 February in leap years) by ministerial order since the most recent reform — earlier deadlines (the 31 January window used until 2017) have been retired in the current calendar.

For 2026, the window is 1–28 February 2026, reporting operations during calendar year 2025. There is no extension. Filing on 1 March is already late, even by a day. Because the deadline overlaps with Modelo 390 (annual VAT summary) and the rush to prepare year-end accounts, plan invoice reconciliation with major clients in early January, not late February.

Who This Guide Is For — Eight Common Profiles

Modelo 347 sweeps in almost every expat-run business in Spain. If any of these descriptions applies to you, this guide is directly relevant.

• UK or US autónomos with Spanish clients. If you bill any single Spanish client more than €3,005.06 in a year (VAT in), you both declare each other.
• Consultants and freelancers on régimen general. The default IRPF and VAT setup for most expat professionals. You file Modelo 347 if a single client crosses the threshold.
• SL (Sociedad Limitada) owners. Every Spanish limited company files Modelo 347 for clients and suppliers over the threshold, regardless of size.
• Property landlords with commercial tenants. Rental income from a commercial lease over €3,005.06 in the year is reportable. Residential leases to private individuals are typically excluded under the retentions rule.
• Holiday rental operators. Bookings via Booking, Airbnb or Vrbo — if you cross €3,005.06 of services received from the platform, the platform is declared as a supplier.
• Small e-commerce sellers. Marketplace fees (Amazon, eBay, Etsy) over the threshold are declarable supplier operations.
• Professionals with a single major client. Consultants billing one Spanish company most of the year almost always cross the threshold and end up on each other's Modelo 347.
• Comunidades de bienes and joint autónomos. Civil partnerships and joint professional set-ups file as a single entity through their own NIF.

How to File Modelo 347

Filing is electronic only, via the Agencia Tributaria's sede electrónica. There is no paper form and no in-person filing.

1. Obtain digital identification — a certificado digital, DNIe or Cl@ve PIN. The digital certificate is the most universally useful for businesses.
2. Reconcile your books with major counterparties in January — circulate a list of totals by quarter to your top clients and suppliers and resolve any differences before either of you files.
3. Generate the data file from your accounting software — most Spanish accounting packages (Sage, Holded, A3, Quipu, Contasol) export a Modelo 347 XML file directly.
4. Access the form via the official Modelo 347 page with your digital credential.
5. Upload the XML or enter records manually — for a handful of counterparties, manual entry is faster than wrestling with software exports.
6. Validate, sign and submit electronically — keep the justificante as your proof of filing.
7. Retain underlying invoices and ledgers for at least four years from the filing deadline.

Most autónomos file through their gestoría or asesoría fiscal — preparation is typically bundled with the year-end accounts and Modelo 390 (annual VAT summary). For specific queries, you can book a cita previa at your local Agencia Tributaria office via the cita previa portal. The autónomos federation ATA also publishes practical guidance for self-employed filers each January.

Penalties and the Paralela Letter

Modelo 347 sits within the general penalty framework of the Spanish General Tax Law (Ley General Tributaria). It is an informational return, so penalties are not tied to unpaid tax — they are fixed amounts per data point, with minimums and maximums.

Failure to file or late filing. The base penalty is €20 per record (per counterparty) omitted or filed late, with a minimum of €300 and a maximum of €20,000. Voluntary late filing — before any Agencia Tributaria notice — typically attracts a 50% reduction on the penalty, sometimes more under the current regularisation regime.

Inaccurate or incomplete filing. Fines for incorrect, incomplete or false records run at a similar level — typically €150 to €6,000 depending on the volume and gravity of the errors.

The paralela letter. Far more common than a formal penalty is the paralela — a computer-generated enquiry letter sent when your declared totals do not match your counterparty's. The letter is not a fine. It is a request to explain the difference. In most cases, a short written reply with copies of the relevant invoices closes the matter. Ignoring the paralela, however, escalates to formal procedure and potential fines.

Six Common Mistakes That Trigger Paralelas

The single biggest cause of Modelo 347 problems is not malice or evasion — it is the timing and recording differences between two parties to the same invoice. These six mistakes account for the great majority of paralela letters issued each year.

Reconciling With Major Clients and Suppliers Before You File

The single most useful Modelo 347 habit is a January reconciliation pass with your top counterparties. The objective is not to share confidential figures — it is to agree, by quarter, the totals each side will declare. A simple email saying "for Modelo 347 we will declare €18,420 with quarterly split Q1 €4,200, Q2 €4,500, Q3 €4,900, Q4 €4,820 — can you confirm these match your books?" prevents the paralela before it is generated.

Where the totals differ, the typical causes are:

• Invoices issued late in December and recorded by the other side in January.
• Credit notes or rebates one side has applied and the other has not yet recorded.
• Bank charges, factoring fees or platform commissions netted off one side and grossed up the other.
• Equivalence surcharge (recargo de equivalencia) applied to retail purchases where the supplier is on régimen general.
• VAT under criterio de caja on one side and ordinary accrual on the other — invoice recognised in different quarters.

Modelo 347, Autónomos and Insurance — Where the Lines Cross

For expat autónomos and SL owners, Modelo 347 sits inside a broader Spanish compliance and risk picture. The same set-up that produces a Modelo 347 obligation — a viable economic activity, regular clients, real invoices — also produces a set of insurance requirements: professional indemnity (responsabilidad civil profesional) for advisory work, public liability for client-facing premises, and health cover for the autónomo and family.

The Spanish insurance regulator (DGSFP — Dirección General de Seguros y Fondos de Pensiones) authorises every insurer permitted to operate in Spain. Policies sold through a DGSFP-registered broker carry the consumer protections of the Spanish regime — which is why we only place business with DGSFP-authorised insurers. See our autónomo insurance guide and our business insurance overview.

Related Forms — 303, 390, 349 and 184

Modelo 347 is one of a cluster of VAT and informational forms. Understanding how they connect avoids the most common cross-form errors.

• Modelo 303 — quarterly VAT return (April, July, October, January). The source data for Modelo 347.
• Modelo 390 — annual VAT summary, also filed in January. Should reconcile back to the four quarterly Modelo 303s and forward to Modelo 347.
• Modelo 349 — recapitulative declaration of intra-EU acquisitions and supplies. EU operations go here, not on Modelo 347.
• Modelo 184 — annual return for entities in attribution of income (comunidades de bienes, civil partnerships). The members' shares are reported here.
• Modelo 190 — annual summary of withholdings on professional fees, rent and salaries. Withheld payments are excluded from Modelo 347.

Key Takeaways

• Modelo 347 is mandatory for autónomos and companies with any single counterparty totalling more than €3,005.06 (VAT included) in the calendar year.
• The threshold is per counterparty, per year, gross of VAT — not per invoice, not net, not aggregate across all clients.
• The filing window is February, reporting the previous calendar year. No extensions.
• Modulos, REAGP, equivalence surcharge and SII users are exempt for activities within those regimes.
• Each counterparty is reported with a quarterly breakdown — the totals must match the other side's filing or a paralela letter is generated.
• Reconcile with major clients and suppliers in January before either side files — this prevents the great majority of paralelas.
• Penalties run €20 per omitted record with a €300 minimum, reduced for voluntary late filing.
• Filing is electronic only via the Agencia Tributaria sede, using a digital certificate, DNIe or Cl@ve PIN.