Modelo 232: informative return of related-party transactions and with non-cooperative jurisdictions

What you need to have at hand

1. NIF of the filer and exact dates of the fiscal year (start/end).
2. List of related parties: NIF/NIE or foreign ID, name and country.
3. Summary by type of transaction (services, loans, purchases/sales, transfers) and valuation method.
4. Contracts, invoices and intragroup settlements to reconcile figures.
5. If applicable: transactions with non-cooperative jurisdictions (counterparty, country and amounts).
6. Transfer pricing documentation (local file/master file) if you are obliged.

Documentation

• Annual accounts for the fiscal year to verify totals.
• Breakdown of each aggregated related-party transaction by type and valuation method.
• Full identification of each related party (NIF/NIE or foreign ID, country, type of link).
• Details of advance pricing agreements (APA) if any exist.
• Basic evidence (contracts, invoices) in case you need to justify amounts during validation.

Step by step

1. Go to the Sede de la AEAT: Modelo 232: https://sede.agenciatributaria.gob.es/Sede/impuesto-sobre-sociedades/modelo-232.html
2. Identify with Cl@ve (individuals) or certificate/DNIe. If you are a company, use the representative’s certificate.
3. Open the form for the year and fill in “Datos del declarante y período”.
4. In “Operaciones vinculadas”, add each related party and complete aggregated amounts by type and valuation method. Don’t enter loose figures without grouping.
5. If you have transactions/situations with non-cooperative jurisdictions, fill their section with counterparty, country and amounts.
6. Click “Validar”, review notices and correct. If you must leave, use “Guardar” to download the draft (.ses) and later “Cargar” to resume.
7. Sign and send. Download the receipt (PDF) and the CSV. Save them with the fiscal year in the file name.

Time-savers

• Prepare an Excel with columns: related party, country, operation type, method, amount. You’ll copy-paste without thinking.
• If you’re unsure about thresholds, aggregate by type and counterpart: you’ll see quickly if you must file and avoid unnecessary submissions.
• Keep the list of valuation methods handy. Choosing the right one avoids dumb errors.
• File a few days before the deadline: the Sede gets overloaded on the last day and may drop your session.
• If your adviser files, grant apoderamiento in advance: https://sede.agenciatributaria.gob.es/Sede/apoderamientos.html

Typical mistakes that can mess up the filing

• Filing late: fines and wasted time in appeals.

• Trying to use Cl@ve for a company: you’ll be blocked. You need the representative’s certificate.

• Mixing different operations on one line: the form requires aggregation by type and method; mixing triggers errors.

• Forgetting transactions with non-cooperative jurisdictions: even small amounts can be reportable.

• Not saving the receipt with the CSV: if they ask for the acknowledgement, you’ll have to dig it out of the Sede and waste time.