As November begins, the finance departments of companies and corporate groups face a key milestone in the annual tax calendar: filing Form 232, the informative return on related-party transactions and on transactions with non-cooperative countries or territories.
Unlike quarterly tax returns, Form 232 does not involve paying any tax. However, its legal importance is enormous: it is the main tool the Spanish Tax Agency uses to gather structured information and select the companies that will be reviewed or audited for transfer pricing and related-party transactions.
At Ruiz & Asociados we explain which entities must file it this November 2026, which transactions must be included and how to make sure the data matches the company’s accounts.
🔍 Who must file Form 232 in November?
The filing period for Form 232 covers the whole month of November (the eleventh month after the end of the tax period for companies whose financial year matches the calendar year).
Corporate Tax and Non-Resident Income Tax (with a permanent establishment) taxpayers must file this informative return if they have carried out the following transactions:
FORM 232 REPORTING THRESHOLDS
┌────────────────────────────────────────────────────────────────────────┐
│ 1. GENERAL LIMIT │ Transactions with the same related party │
│ > €250,000 │ of the same type and valuation method. │
├───────────────────────────┼────────────────────────────────────────────┤
│ 2. SPECIFIC TRANSACTIONS │ Sales of property, shares or intangibles │
│ > €100,000 │ between related parties. │
├───────────────────────────┼────────────────────────────────────────────┤
│ 3. SPECIFIC METHODS │ Transactions of the same type exceeding │
│ > 50% of turnover │ 50% of turnover. │
├───────────────────────────┼────────────────────────────────────────────┤
│ 4. NON-COOPERATIVE │ Transactions or securities in non- │
│ JURISDICTIONS │ cooperative countries, whatever the amount.│
└───────────────────────────┴────────────────────────────────────────────┘
⚠️ The 4 critical areas the Tax Agency focuses on
When preparing Form 232, you must review in detail the transactions carried out during the year, paying particular attention to four recurring areas:
1. Loans and financial contributions between shareholders and the company
Financing between shareholders and companies (or between subsidiaries) must report the interest rate applied, the outstanding principal and the valuation method used. The agreed interest rates must be supported by the corresponding market comparison analysis.
2. Management fees and intra-group services
Invoicing of management or administrative support fees from holding companies to their subsidiaries is closely scrutinised. Besides reporting the amount in Form 232, the company must have documentation proving that the service was actually provided and that the subsidiary really benefited from it.
3. Property rentals between related parties
Renting premises, offices or industrial buildings owned by shareholders or related holding companies requires reporting the annual amount and checking that the rent is in line with average rents in the area.
4. Pay for directors and governing bodies
In family businesses subject to a family protocol and succession plan, the pay of board members with management functions must be properly reported and aligned with the valuation required to keep the wealth tax exemption.
💻 Automated data matching and consequences of not filing
In 2026 the AEAT uses artificial intelligence algorithms that automatically cross-check the data reported in Form 232 with:
- The related-party transaction boxes of Form 200 (Corporate Tax).
- The withholdings reported in Forms 111 and 190.
- The internal documentation file (Local File and Master File).
Filing Form 232 late, leaving out mandatory transactions or including data inconsistent with the official accounts leads to tax penalties and automatically triggers requests through the DEHú and electronic notifications.
Keeping these files in order is also essential during the weeks of year-end tax planning, so that the accounts can be closed without hidden contingencies.
To review the rules governing this informative return, you can consult Order HFP/816/2017 approving Form 232 in the Official State Gazette or the guides of the Spanish Tax Agency.
🏢 Ruiz & Asociados: preparing and reviewing Form 232
At Ruiz & Asociados we have a team of economists and tax advisers specialised in transfer pricing and tax compliance for corporate groups. 🤝
We review your company’s transactions, check the reporting thresholds, adapt valuations to arm’s length criteria and file Form 232 electronically to give your organisation complete peace of mind and legal certainty.
Are you sure which related-party transactions you must report this November? Avoid requests and penalties. Contact our firm today and leave your informative return in the hands of specialists. 🚀
