For VAT-registered businesses in Spain, the annual VAT return is a key compliance step that reconciles the entire year’s VAT activity.
In addition to periodic VAT filings, most businesses must submit an annual summary return the Modelo 390, most Spanish VAT-registered businesses must submit an annual summary return known as the Modelo 390 to reconcile all the VAT activity reported during the year.
What Is the Annual VAT Return (Modelo 390)?
The Spanish annual VAT return is a recapitulative summary of all VAT figures included in your periodic VAT returns throughout the year. It consolidates total taxable sales, purchases, VAT collected, VAT paid, including taxable, exempt, and zero-rated transactions reported during the year.
The Modelo 390 is primarily an informational return used by Agencia Tributaria to reconcile annual VAT data.
Deadline for Filing
For most VAT-registered businesses in Spain, the annual VAT return covering the 2025 reporting period must be filed by January 30, 2026. The filing deadline is 30 January 2026 for the 2025 reporting year.
The return must be filed electronically using approved digital authentication methods.
Who Is Required to File an Annual VAT Return?
Most VAT-registered businesses in Spain are required to file Modelo 390, unless they fall under specific exemptions.
- Companies using SII (Immediate Information System): Businesses that submit detailed invoice information regularly under SII do not need to file the annual summary.
- High-turnover entities: Large companies (often those with annual turnover exceeding approximately €6 million) are typically covered by SII or other regimes that exempt them from Modelo 390.
- REDEME and certain special regimes: Participants in the Monthly Refund Program or simplified property-related VAT regimes may not be required to file the annual VAT return.
In these cases, the details normally captured in the annual report are either already provided through detailed reporting channels or are embedded within the last periodic VAT return of the year.
What to Include in Your Annual VAT Return
The annual return should accurately consolidate the following:
- Total annual VAT collected and paid during the year
- Summary of transactions (sales, purchases, exempt supplies) across all periodic returns
- Exempt or zero-rated supplies that may not appear in regular return totals
- Adjustments or corrections made in quarterly or monthly filings
If your company has a refund position (i.e., VAT paid on purchases exceeds VAT collected on sales), Any refund position or carried-forward VAT credit should be clearly reflected and documented.
Common Modelo 390 Filing Risks to Avoid
- Failing to File Even With No Activity:
Even if your business had no chargeable transactions in some periods, a nil annual return may still be required if you are subject to the obligation and not exempt. - Reconciling with Periodic VAT Returns:
Amounts in Modelo 390 must be consistent with figures reported throughout the year in your quarterly or monthly VAT returns (Form 303 or equivalents). Discrepancies can trigger compliance reviews or notices. - Electronic Submission Is Mandatory:
There is no paper filing option — all annual VAT returns must be submitted online through the Spanish Tax Agency’s platform with approved digital credentials. - Deadline Adjustments:
Although deadlines may shift for holidays, relying on extensions increases risk of late filing.
Why the Annual VAT Return Matters
Modelo 390 acts as a reconciliation control for Spanish VAT reporting and is often used to identify inconsistencies across filings. It acts as a critical compliance safeguard — helping authorities verify that periodic VAT returns and annual activity align. Accurate filing reduces audit risk, penalty exposure, and follow-up queries.
Supporting Accurate and Consistent Spanish VAT Reporting
Annual VAT compliance is not just about submission — it is about ensuring year-end consistency across all VAT filings.
At Safari Star, we provide VAT compliance support including:
- Annual VAT return preparation and review
- Reconciliation of periodic VAT filings
- Electronic submission support with secure tax credentials
- Strategic advice on whether your entity qualifies for exemptions or simplified regimes
- VAT planning to optimize credit positions and refund opportunities
Early reconciliation and review help businesses avoid corrections, penalties, and unnecessary audits.