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A lawyer asks whether invoices where clients have already applied IRPF withholding and declared them in Form 190 must be included in the annual informative return of transactions with third parties (Form 347). The DGT responds that it is not mandatory to include them if the information is already provided specifically in other tax returns.
Cuestión planteada
Las operaciones que ya se declaran mediante una obligación periódica de suministro de información con contenido coincidente quedan excluidas del modelo 347. En concreto, las operaciones declaradas en la declaración anual de retenciones e ingresos a cuenta (modelo 190) no deben incluirse en la Declaración Anual de Operaciones con Terceras Personas. Esto responde al principio de limitación de costes indirectos derivados del cumplimiento de obligaciones formales.
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