This November marks the end of the filing period for Form 232 for the 2024 fiscal year, applicable to companies whose financial year closes on December 31. Now is the time to confirm whether your company is required to file this informative return and, more importantly, ensure you have all the necessary documentation for your related-party transactions.

What is Form 232 and who needs to file it?

Form 232 is an informational return used to report related-party transactions to the Spanish Tax Authority.

These are transactions between a company and individuals or entities with which it has a special relationship — such as directors, shareholders, their relatives, or companies in which they have an interest or control.

You must file Form 232 if your company meets any of the following conditions:

  • Transactions exceeding €250,000 in total with the same related party.
  • Specific transactions over €100,000 (such as business transfers, real estate, or intangibles).
  • Transactions of the same type and valuation method that represent more than 50% of your company’s turnover.
  • Any transactions with entities located in tax havens, regardless of the amount.

Remember: transactions must be valued at arm’s length — the same terms that would apply between independent parties.

Penalties for non-compliance

Failure to file or incorrect filing may result in penalties of €20 per missing or incorrect item (minimum €300, maximum €20,000). Late filing without prior notice may benefit from a 50% reduction.

Are there any other obligations regarding related-party transactions?

Yes. While Form 232 serves as an informational return, companies are also required to maintain proper transfer pricing documentation — an obligation that is often overlooked.

This documentation must demonstrate that transactions have been priced at arm’s length and must be available to the Tax Authority once the Corporate Income Tax filing deadline has passed.

The level of documentation required depends on the group’s annual turnover:

  • Over €45 million: Master File (group documentation).
  • Between €10 and €45 million: Local File (entity documentation).
  • Under €10 million: standardized document included in Form 200 (Corporate Income Tax return).

Note: Form 232 and transfer pricing documentation are independent requirements — one reports, the other supports.

Consequences of inadequate documentation

Penalties for missing or incomplete documentation can be substantial:

  • Without value adjustment: €1,000 per missing item (up to €10,000).
  • With value adjustment: 15% of the adjusted amount.

Why it pays to act early

With the filing deadline approaching, now is the ideal time to meet this reporting requirement and review your transfer pricing documentation.

A well-prepared Local File, Master File, or standardized report not only helps avoid penalties but also serves as a strong defense during a tax audit.

At addwill, we have extensive experience in transfer pricing analysis and documentation. We can help your company ensure full compliance and assess your specific situation. Contact us through our online form to learn more.