On November 18, 2017, Order HFP/1106/2017 of the Ministry of Finance and Public Administrations was published in the Official State Gazette, establishing changes in model 190 and modifying the deadlines for submission of Finance forms 347, 171, 184, and 345. Do you want to be aware of all these news? Continue reading.

In this article we offer you a practical summary of who are the taxpayers obliged to present each of these models to the Treasury and at what time of the year they must do so, after the announced changes.

Changes in the presentation of Form 190

As we have anticipated, the order recently published in the Official Gazette established certain modifications in the Model 190.

This model corresponds to “the declaration of the annual summary of withholdings and income on account of the Personal Income Tax on income from work and economic activities,prizes and certain capital gains and income imputations”.

That is, it is an annual summary of Form 111 by which both companies and the self-employed and other obligated liquidate the withholdings derived from items such as employee payrolls, withholdings in invoices for professional fees, prizes and certain capital gains.

Changes in the model have to do with certain modifications in the regulations, inaddition to modifications in the physical and logical designs (for example, scholarships exempt from declaration or the possibility of introducing an email from the contact person).

The main changes are:

  • Deletion of paragraph 2 of the order which provided: “Notwithstanding the provisions of the previous section, in the case of scholarships exempt under the provisions of articles 7.º j) of the Law and 2.º of the Regulation, both of the Tax, those whose amount is less than 3,000 euros per year will not be included in the form 190”.
  • The new model 190 replaces the model in Annex I of Order EHA/3127/2009 with that of Model 190 in Annex I of this Order.
  • In the physical and logical designs, a new field “Email of the person with whom to relate” of the Registration Type 1 is incorporated: “Declarant Record”.
  • New fields are incorporated to differentiate between monetary and in-kind perceptions derived from incapacity for work and those that do not derive from incapacity for work.

As for the term, Form 190 must be submitted from January 1 to 31 of each year,for the withholdings and income on account corresponding to the previous year.

The new deadlines for submission of Treasury forms 171, 184, 345 and 347


For their part, taxpayers should pay close attention to Order HFP/1106/2017 because it modifies the deadlines for submitting very important models.

In fact, the modification established by the Treasury with respect to the deadlines for submission has reached the following models: 171, 184, 345 and 347.

In this context, it is worth remembering which declarations these models correspond to so that those who are among the obligated subjects become aware of the new deadlines.

Model 171

⇒ What is it?

It is the model that corresponds to the annual informative declaration of impositions, dispositions of funds and collections in any document.

Who is required to submit it?

It must be presented by credit institutions and all those entities dedicated to banking or credit traffic.

What is declared?

The impositions, dispositions of funds and the collections are declared in any document when its amount is greater than € 3,000,identifying who is the one who carries out the operation.

⇒ New submission date:

Previously, the presentation of The Model 171 was made between March 1 and 31 of each year for the operations of the previous year.

From the modification of the term established by the Treasury, Form 171 must be submitted between January 1 and 31 of each year.


Model 184

⇒ What is it?

Through this model, the annual informative declaration that must be made by the entities under the income attribution regime is presented.

⇒ Who is required to submit it?

The income attribution regime was created to subject certain companies that are exempt from the payment of Personal Income Tax and also from Corporation Tax to taxation.

Thus, these companies must present Form 184 whenever they have economic activity in the country and their operations exceed the sum of € 3,000.

⇒ What is declared?

Income from real estate and furniture capital, economic activities and capital gains and losses are declared.

⇒ New submission date:

The deadline for filing Form 184 has also been modified. Previously, it had to be done within the period from 1 to 28 February for the figures corresponding to the previous year. Since the recent order, the presentation must be made between January 1 and 31 of the year.


Model 345

⇒ What is it?

Form 345 is the annual declaration of pension plans,alternative systems, social security mutual societies, insured pension plans, individual systematic savings plans, business social security plans and dependency insurance.

⇒ Who should submit it?

  • Pension fund management entities;
  • Pension plan promoters;
  • Entities covered by alternative benefit systems similar to those of pensions and mutual societies.

⇒ New submission date:

The deadline for submission of this Model has been modified to the period between January 1 and 31 of each year.


Model 347

⇒ What is it?

Through it, the annual declaration of operations with third parties is presented.

⇒ Who is required to submit it?

All natural or legal persons, public or private, who carry out professional or business activities and who, by reason of these activities, have carried out operations with another person or entity that, as a whole, have exceeded € 3,005.06are obliged to this declaration.

⇒ New submission date:

Form 347 must also be submitted between January 1 and 31 of each year,for the operations corresponding to the previous year.

It will enter into force on January 1, 2018,and will be applicable in the declaration of the year 2018 and following.


In conclusion, in addition to the changes introduced in the Model 190, new deadlines have been established for models 171, 184, 345 and 347:all must be submitted between January 1 and 31 of each year for the operations corresponding to the previous year.

For more information, consult the complete standard in the Official State Gazette following this link and do not hesitate to obtain the tax advice of AYCE LABORYTAX.