B Law & Tax
04 December 2023

Tax advisor: Tax Reforms 2023: Significant Changes in Models 190 and 270

In this article, we will be talking about Models 190 and 270 .  The Order HFP/1286/2023, published on November 30, 2023, introduces changes to Model 190 for the annual declaration of withholdings and payments on account of the Personal Income Tax. These modifications affect Order EHA/3127/2009, dated November 10. Additionally, Order HAP/2368/2013, which approves Model 270 for the “Annual Summary of Withholdings and Payments on Account,” is also impacted. The special tax applicable to prizes from certain lotteries and bets is also affected, with specific regulations introduced for its presentation.


Changes in Model 190 according to Order EHA/3127/2009, dated November 10:

  1. Expansion of perception categories in the “Perception Key” field of Form 190:

    Codes “F,” “G,” and “I” are added with subcategories to address new withholding cases introduced by the General State Budget Law for 2023, such as 7% on work income for the assignment of rights to literary works or 15% on intellectual property income.

  2. Adjustments in contract or relationship types in the “Contract or Relationship” field of Form 190:

    These changes reflect the modification of Royal Decree 31/2023, expanding cases subject to a minimum withholding rate of 2%, including contracts arising from special employment relationships in the performing arts, audiovisual, and musical sectors.

  3. Detailed breakdown of SEPE benefits and subsidies:

    A more specific breakdown is made of benefits paid by the State Public Employment Service, including collective dismissals, amounts for self-employed workers due to cessation of activity, unemployment benefits, and active insertion income.

  4. Distinction for residents on the island of La Palma:

    A new deduction for the habitual residence in La Palma is introduced for the fiscal years 2022 and 2023, with terms and conditions similar to the deduction for income in Ceuta or Melilla.

  5. Creation of subcategories in the “L” code:

    Two new categories are added to differentiate exempt fringe benefits, in response to the modification of the Startup Law, which raises the exempt limit to 50,000 euros for fringe benefits derived from the delivery of shares or participations.

  6. New field for withholdings and payments on account:

    An additional field called “Withholdings and payments on account paid in the State, in the regional governments of the Basque Country and the Foral Community of Navarre” is incorporated, and it will only be filled for benefits classified under the “E” code.

  7. Change from the term “degree of disability” to “degree of disability”:

    References to the term “degree of disability” are replaced with “degree of disability,” following Royal Decree 888/2022, which regulates the procedure for recognizing and assessing the degree of disability.


Changes made to Model 270 according to Order HAP/2368/2013, dated December 13:

  1. Modification in record type 1:

    Allows the declarant to indicate whether the information is provided monthly or annually, resulting from agreements between the Tax Agency, the state entity responsible for lotteries and betting, SME, SA, and the national organization for blind people in Spain.

  2. Implementation of agreements:

    According to the agreement between the Tax Agency and the State Society of Lotteries and Betting of the State, SME, SA, from 2023, this operator will fulfill the obligation to submit model 270 to avoid duplications in the information.

  3. Agreement with the National Organization of Spanish Blind People:

    The obligation to submit model 270 for withholdings and payments on account of the special tax on prizes will be fulfilled by this operator from 2024 through the submission of telematic information in accordance with the agreement.



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