Spanish Form 111 (Modelo 111) is the quarterly tax return for withholdings and payments on account of personal income tax (IRPF) filed by Spanish companies, self-employed individuals, and professionals who have withheld amounts from payroll, professional invoices, prizes, or specific capital gains. Together with Form 303 (VAT), it is one of the Spanish tax returns that generates the most errors and penalties among self-employed and SMEs — particularly due to confusion about who is required to file and discrepancies with the annual summary (Form 190).
This guide explains in detail what Form 111 is, who must file it, the exact 2026 deadlines, how to complete it step by step, the applicable withholding rates, and the frequent mistakes worth avoiding.
What is Form 111?
Form 111 is the periodic tax return for IRPF withholdings and payments on account. Through this form, the payer (the Spanish company, the self-employed person, or the entity paying the income) declares to the Spanish Tax Agency (AEAT) the amounts withheld during the quarter as advance payments of the recipient’s IRPF.
Withholdings function as a prepayment of the IRPF that the recipient will reconcile in their annual return (Form 100). The payer acts as a substitute for the taxpayer: deducts the amount from the salary or invoice and pays it directly to the AEAT. The recipient, when filing their annual IRPF, deducts those withholdings from their final tax bill.
The legal basis of Form 111 is found in:
- Article 99 of Law 35/2006 on Personal Income Tax (LIRPF), establishing the general obligation to withhold.
- Articles 74 to 100 of the IRPF Regulation (Royal Decree 439/2007), regulating the withholding rates applicable to each income type.
- Order HFP/1335/2021 (and its annual updates), approving the official form and the electronic format.
Who must file Form 111
Mandatory filers
All payers that practise withholdings or payments on account of IRPF are required to file Form 111:
- Spanish companies with employees: SL, SA, cooperatives, and other legal entities paying salaries to employees, with withholdings calculated using the annual IRPF scales.
- Self-employed with employees: sole traders or professionals with employees, practising withholdings on payroll.
- Self-employed and companies receiving invoices from Spanish professionals with withholding: when contracting services from Spanish lawyers, advisors, architects, consultants, commercial agents, etc. The withholding applies to the taxable base (not the total with VAT) and is paid through Form 111.
- Owners’ associations with employees: porters, administrators with employment relationships, concierges.
- Non-profit entities with staff: associations, foundations, NGOs.
- Payers of taxable prizes: when prizes in cash or in kind exceed the exempt thresholds.
Exceptions and special cases
- Quarter without withholdings: if no withholdings have been practised in a quarter, filing Form 111 is not mandatory (except for large enterprises, which must file a nil return).
- Non-business individual client: when the invoice recipient is neither a business nor a professional, no withholding applies and the professional does not include withholding in the invoice.
- Operations between professionals under the same regime: the recipient practises withholding only if they have the status of business or professional for IRPF purposes.
2026 Quarterly deadlines
| Quarter | Period | Filing deadline |
|---|---|---|
| Q1 | January – March 2026 | 1 to 20 April 2026 |
| Q2 | April – June 2026 | 1 to 20 July 2026 |
| Q3 | July – September 2026 | 1 to 20 October 2026 |
| Q4 | October – December 2026 | 1 to 20 January 2027 |
If the last day of the deadline falls on a Saturday, Sunday, or national holiday, the due date moves to the following working day.
Large enterprises (turnover above €6 million in the preceding fiscal year): file Form 111 with monthly periodicity, within the first 20 calendar days of the month following the liquidation period.
Filing is mandatorily electronic for all filers, through the AEAT Electronic Headquarters, using electronic certificate, electronic national ID (DNIe), Cl@ve PIN, or, for individuals, equivalent enabled systems.
What withholdings are reported in Form 111
Form 111 aggregates several withholding concepts. The main categories are:
Personal employment income (codes A and B in the annual summary 190)
- Salaries and wages of active personnel (code A)
- Pensions and retirement benefits (code B)
- Arrears attributable to previous fiscal years
- Extra pay and assimilated remuneration concepts
- Severance amounts within the exempt limits (Article 7.e LIRPF) are not included
The withholding on payroll is calculated by applying the corresponding rate from the Withholding Algorithm published annually by the AEAT, based on foreseeable annual gross salary, family situation (descendants, ascendants, disability, alimony payments), and other factors. The payer must give the recipient the withholdings certificate (Form 145) at the start of the year and communicate the applied percentage.
Professional services income (codes G and H)
The withholding rate on invoices from Spanish professionals is:
- General rate: 15% on the taxable base (excluding VAT).
- Reduced rate: 7% during the year of commencement of activity and the following two years, for professionals who have not exercised any professional activity in the year preceding the start. The professional must communicate in writing to the payer their right to the reduced rate.
- Specific rates: 2% for certain agricultural and livestock activities, 1% for municipal collectors and commission agents in specific cases.
Prizes and assimilated gains (code I)
Cash or in-kind prizes subject to withholding: the applicable rate is 19% on the amount exceeding the €40,000 exempt threshold (Law 16/2012, modified by successive Budget Laws).
Capital gains from forestry exploitation (code K)
Forestry exploitation in communal mountains: withholding of 19%.
Assignment of image rights (code L)
Consideration derived from the assignment of image rights: withholding of 24%, regulated in Article 92 of the LIRPF.
How to complete Form 111 step by step
The official form has several sections. These are the most relevant:
Identification section
- Filer’s tax ID (NIF), company name, or first and last name.
- Fiscal year and period (Q1, Q2, Q3, Q4 or, for large enterprises, the corresponding month).
- Complementary return indicator (only if rectifying a previous self-assessment).
Tax liability calculation
The form groups withholdings by income type:
| Box | Concept | Meaning |
|---|---|---|
| 01 | Employment income — number of recipients | Total people receiving employment income in the quarter |
| 02 | Employment income — gross amount | Sum of bases subject to withholding |
| 03 | Employment income — withheld amount | Sum of withholdings on employment income |
| 04 | Professional services income — number of recipients | Total professionals invoiced in the quarter |
| 05 | Professional services income — gross amount | Sum of taxable bases (excluding VAT) |
| 06 | Professional services income — withheld amount | Sum of withholdings to professionals |
| 07 | Employment income from courses/conferences/seminars — number of recipients | |
| 08 | Employment income from courses/conferences/seminars — gross amount | |
| 09 | Employment income from courses/conferences/seminars — withheld amount | |
| 10 | Prizes — number of recipients | |
| 11 | Prizes — gross amount | |
| 12 | Prizes — withheld amount | |
| 13 | Capital gains (forestry exploitation) — number of recipients | |
| 14 | Capital gains — gross amount | |
| 15 | Capital gains — withheld amount | |
| 16 | Assignment of image rights — number of recipients | |
| 17 | Assignment of image rights — gross amount | |
| 18 | Assignment of image rights — withheld amount | |
| 28 | Total withholdings and payments on account | Sum of boxes 03 + 06 + 09 + 12 + 15 + 18 |
| 29 | Results to be paid from prior tax returns | Only in complementary returns |
| 30 | Tax return result | Amount payable |
Payment
If the result is positive, payment is made through:
- Bank direct debit (if filed within the first 15 days of the deadline).
- NRC (Complete Reference Number) obtained from the financial institution after making the payment.
- Direct electronic payment from the AEAT Electronic Headquarters.
Common mistakes in Form 111 filing
These are the failures most frequently detected by the AEAT in Form 111 verifications:
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Applying the 7% rate without entitlement to the reduced rate: the professional must communicate in writing they are a new self-employed in their first 3 years and have not exercised professional activity in the preceding year. Without this documented communication, the payer must apply the 15% general rate.
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Calculating withholding on the total invoice with VAT: withholding applies to the taxable base (excluding VAT). Applying it on the total with VAT means over-withholding, and the professional can claim the difference back.
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Not including personnel withholdings from courses/conferences in a separate box: withholdings from courses, seminars, or conferences are declared in boxes 07–09, not in the ordinary personal employment boxes.
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Mismatches between quarterly Form 111 and annual Form 190: the sum of the four quarterly Forms 111 must match the annual Form 190 exactly. Differences trigger AEAT verification proceedings.
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Not withholding to the advisor or lawyer due to lack of awareness: many self-employed do not practise withholding to the professionals invoicing them, assuming it is enough to pay the VAT. The AEAT can demand the unpracticed withholding from the payer (jointly liable), plus penalties.
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Not filing in a quarter with withholdings even if the amount is small: there is no minimum threshold. If at least one withholding was practised in the quarter, Form 111 must be filed.
Penalties for non-compliance
The sanctions framework applicable to Form 111 is in the General Tax Law (Law 58/2003), primarily Articles 27, 191–198, and 209 LGT:
Late filing without prior requirement (surcharges of Article 27 LGT)
- 1% per complete month of delay during the first 12 months.
- 15% + interest on arrears after 12 months.
- If the full amount is paid alongside the filing, there is no additional penalty.
Filing after requirement (penalties of Article 191 LGT)
- Minor infraction: proportional fine of 50% on the unpaid amount, without economic harm to the Treasury. Minimum €200.
- Serious infraction: proportional fine of 50% to 100% on the unpaid amount, when concealment or use of false invoices exists.
- Very serious infraction: proportional fine of 100% to 150% when fraudulent means are appreciated.
Applicable reductions
The regulations allow penalty reductions:
- 30% for conformity with the regularisation proposal.
- 40% additional (cumulative) for prompt payment within the penalty proposal deadline.
- 65% if an acta of agreement or conformity is signed and the amount is paid or guaranteed.
Criminal liability
If the amount defrauded by unpaid withholdings exceeds €120,000 per fiscal year, the conduct may be classified as a crime against the Public Treasury (Article 305 of the Spanish Criminal Code), with penalties of 1 to 5 years of prison and a fine of one to six times the amount defrauded.
How BMC helps with Form 111
At BMC Consulting we manage quarterly Form 111 compliance for foreign-owned companies operating in Spain, Spanish subsidiaries of multinational groups, self-employed individuals, and SMEs. Our service includes:
- Correct withholding calculation on payroll in coordination with labour advisory, ensuring application of updated scales and reductions for family circumstances.
- Verification of withholding rates to professionals: identifying professionals entitled to the 7% reduced rate and documenting the communication to the payer.
- Electronic preparation and filing of quarterly or monthly Form 111 (large enterprises), with bank direct debit of the amount payable.
- Reconciliation of annual Form 190 with the sum of the four quarterly Forms 111, avoiding the mismatches that trigger AEAT verifications.
- Defence in AEAT verifications and inspections related to IRPF withholdings, filing allegations and administrative appeals where appropriate.
If you have doubts about the withholdings you must practise to your employees or professionals, or need to outsource quarterly Form 111 management, contact our tax team at BMC Consulting.
