Spain: Prior notification regarding model 231

published on 04 December 2019

Any entity belonging to a corporate group required to file the Country-by-Country Report (hereinafter “CbC Report”) i.e. groups with a global turnover equal to or higher than 750 million Euro and which is a tax resident of Spain must file a prior communication to the Spanish Tax Authority (AEAT).

A specific standardised form is available in the website of the Spanish Tax Authority (i.e. Sede Electrónica): the prior communication of the Tax Form 231 (Modelo 231).

This communication must include the following information:

• Type of filing (i.e. in own name or by representation), tax identification number (hereinafter, “TIN”) and corporate name of the party concerned.
• Identification of the entity filing the communication (corporate name, TIN and tax period).
• Corporate name of the Ultimate Parent of the corporate group.
• Country of tax residence of the Ultimate Parent of the corporate group.
• TIN of the Ultimate Parent of the corporate group in its residence country.
• Corporate name of the reporting entity of the group.
• Country of residence of the reporting entity of the group.
• TIN of the reporting entity of the group in its country of residence.
• Conditions under which the CbC Report is filed (Ultimate Parent, required subsidiary or subrogated entity).

This communication must be filed each year before the end of the tax period.