Modelo 390: the annual VAT summary, box by box

What modelo 390 is and why the tax agency wants it

Modelo 390 is the annual summary return for VAT. The obligation is born in the VAT Law itself: article 164.One.6 requires taxable persons to file their periodic returns and pay the tax, and adds in a separate paragraph that they "must file an annual summary return". The Regulation develops it in article 71.7: in addition to the periodic returns, "taxable persons must complete an annual summary return" in the form and within the deadlines approved by the Ministry.

Three features define it:

• It is informative. Nothing is paid or refunded with it. What was payable or offsettable was already settled in the 303s; the 390 merely recaps.
• It is annual and single. One 390 per year and per tax number, with every activity and every regime inside.
• It is a cross-checking tool. Its boxes replicate, summed, those of the year's 303s, and add data the quarters lack: the breakdown of deductible VAT by rate and by nature, the turnover figure and the specific transactions. The tax agency matches it against the 303s, the VAT record books, the modelo 347 and the modelo 349. When something does not fit, the query usually starts here.

So the right way to think about the 390 is not "one more form" but "the proof that the four 303s were right". If they were, the 390 almost fills itself in. If they were not, the 390 is where it shows.

Who files it and who is exempt

The general rule is broad. Article 71.1 of the VAT Regulation requires businesses and professionals to file the periodic returns and the annual summary "even where no VAT has accrued and no input VAT is deducted". Translated: if you filed 303s during the year, even nil ones, you file a 390. A dormant SL still registered for VAT files a zero 390.

The exemptions are limited and sit in the same article:

• Those carrying out only exempt transactions under articles 20 and 26 of the VAT Law (healthcare, education, residential letting and the like) file neither 303 nor 390 (articles 71.1 and 71.7). What an exempt transaction is, the glossary explains.
• Those in the Immediate Supply of Information system. Article 71.1 allows a ministerial order to exempt taxable persons "in respect of whom the tax administration already holds sufficient information", which is the case of those registered in the SII, who keep their record books on the tax agency's site invoice by invoice.
• Certain quarterly filers whose activity is limited to the simplified regime or the letting of urban property, exempted by the same route. In exchange, they complete an additional information section in the last quarter's 303, where they tick the exemption and declare the year's turnover.

Two points that confuse people. Being exempt is not the same as not being obliged: exempt filers must declare in the fourth-quarter 303 what the 390 would have collected. And the exemption is assessed activity by activity: a landlord of commercial premises who also provides consulting services falls outside the case and files the full 390. When in doubt, the official modelo 390 page on the tax agency's site is the reference.

Deadline and how it is filed

The 390 is filed from 1 to 30 January of the year following the one it summarises, in the same window as the fourth-quarter 303. For 2026, 30 and 31 January 2027 fall on a weekend, so the deadline ends on Monday 1 February 2027. Every form's dates, with their shifts, are in the 2026-2027 tax calendar.

As no payment is involved, there is no direct debit to shorten the window and no payment reference to obtain: the whole of January is yours. But do not leave it for the 30th, because the 390 is filed after the fourth-quarter 303 and has to reconcile with it. The sensible order is to close the December books, file the fourth-quarter 303, and generate the 390 from those now-final figures.

Filing is electronic only, on the tax agency's site: with a digital certificate, which is the route for companies, or with Cl@ve if you are an individual. A gestor or registered agent can also file it on your behalf. One is filed per tax number, however many activities you have, and in it you state whether you are in the monthly refund register, whether you are taxed under the simplified regime or the equivalence surcharge, and whether the year is shorter than twelve months.

How it is built from the four 303s

The 390 has the same architecture as the 303: output VAT at the top, deductible VAT in the middle, result at the bottom. The difference is that here every figure is the year's total and comes broken down in more detail. This table places the main blocks of the general regime with their box numbers:

The cross-check the tax agency runs first, and you must run before it: box 65 of the 390, the result of the general regime, must be exactly the sum of box 46 of the year's four 303s. If it does not match, either a 303 was wrong or the 390 was not built from the same books. Then come the flow checks: box 95 against what you paid, 97 or 98 against the December 303, and 85 against the credit carried from the previous year. You can rebuild a specific quarter with the modelo 303 estimator.

The boxes that cause trouble

Mismatches on the 390 almost never come from a wrong sum. They come from the year, seen whole, bringing to light what the quarters concealed. These are the points where it breaks:

• The credit carried forward (boxes 85, 97). The most frequent error. A first-quarter 303 with a credit that was subtracted twice in the second quarter, or never subtracted, does not unbalance a quarter: it unbalances the year. The 390 forces you to follow the thread of the credit from January to December.
• Capital goods versus current expenses (48 to 51). A computer or a vehicle deducted as a current expense does not change the VAT, but it changes the box, and the tax agency compares that breakdown with the books. The 303 separates them too, so consistency starts in each quarter.
• Adjustments to bases and VAT (29-30). Every credit note of the year has to be here and not mixed with the period's sales. If you issue credit notes, this block has to exist.
• Intra-EU and reverse charge (21 to 28). These boxes are matched against the modelo 349 and against what your European suppliers declared in their country. A purchase from a German supplier on which you did not self-assess shows up in VIES and not in your 390.
• Turnover. The 390 asks for the year's total turnover under article 121 of the VAT Law, which includes transactions that carried no VAT: exempt ones, ones outside the scope under the place-of-supply rules, such as services to businesses in other countries, and exports. Declaring only what carried VAT is the classic mismatch of anyone invoicing abroad.
• Rates no longer in force. The form has dedicated boxes for deductible VAT at rates that have stopped applying, so that input VAT at an old rate does not slip into the rows for current rates.
• Pro rata and regularisation (522 and 63). If you carry out transactions with and without the right to deduct, the year's definitive pro rata is calculated in December and its adjustment is declared here and in the fourth-quarter 303; forgetting it in one of the two is the hardest mismatch to explain afterwards.

What happens if it does not match or you do not file it

If the 390 does not reconcile with the 303s, the first thing is to decide which of the two is wrong, because the fix is different. If the error is in a quarter, the 303 is corrected: since the third quarter of 2024 the route is the rectifying self-assessment, whether the result is more to pay or in your favour. If the error is only in the summary, a replacement 390 is filed, quoting the receipt number of the previous one. Never force the 390 to "match" a wrong 303: you would be signing two returns inconsistent with your books.

If the tax agency spots the mismatch before you do, a formal request arrives asking for clarification or for the record books. You answer within the deadline, with the books, and regularise whatever is due. A mismatch explained and corrected rarely goes further; one ignored opens an audit.

If you do not file it on time, since there is no tax due the surcharge of article 27 of the General Tax Law does not apply; that is for returns with a payment. What applies is the minor infringement of article 198.1 for failing to file a return on time where no economic harm is caused: a fixed fine of 200 euros, halved if you file it yourself before being asked (article 198.2), with the general reductions for acceptance and prompt payment on whatever remains. In other words, a 390 forgotten in January and filed in March on your own initiative costs 100 euros in penalty; the same 390 filed after a request, 200. The mechanics of the reductions and the order of steps when you are late are in the guide to what to do when you miss a deadline.

And a less visible consequence: without a filed 390 the tax agency lacks your annual breakdown, and any VAT refund requested in the fourth-quarter 303 is reviewed more slowly, because the file is incomplete.

How to prepare it painlessly: the December list

The 390 is prepared in December, not January. If you reach 1 January with these points closed, the form is an afternoon's work:

1. Record books closed. Every invoice issued and received during the year entered, with its rate, base and VAT, and credit notes identified as such. The books are the source; the 390 only summarises them.
2. The four 303s added up. Sum box 46 and compare it with the result of the general regime in your 390 draft. If it does not match, stop and find the quarter.
3. The thread of the credit carried forward. Rebuild from January to December what credit came in, what was applied each quarter and what remains at the end. That remainder is your box 97.
4. Cross-check with the 349. The intra-EU acquisitions and supplies in the 390 have to match what was declared in the year's 349s, period by period.
5. Cross-check with the 347. They are not the same figures, because the 347 is VAT-inclusive and per counterparty, but the 390 turnover has to be compatible with what you declare in February.
6. Definitive pro rata. If it affects you, calculate the year's percentage, regularise in the fourth-quarter 303 and carry the same adjustment to the 390.
7. Breakdown of the deductible. Separate current from capital goods, domestic from imports and intra-EU, and check that VAT at rates no longer in force goes to its specific boxes.

All of this is far easier if the books have been kept every month instead of rebuilt in December. The routine that makes it possible is in the guide on how to keep the books.

The 390 in kontora: recomputed from the ledger and cross-checked with your 303s

The reason the 390 is feared is that it is usually done by hand from four PDFs and a spreadsheet. kontora does it the other way round: the annual summary is recomputed live from the year's ledger, the same invoices and expenses that fed each 303, box by box, with the deductible broken down by rate and by nature and the adjustments to bases and VAT re-derived from your credit notes.

Before letting you file, the app runs the cross-check the tax agency would run: it compares the recomputed box 65 with the sum of box 46 of the 303s recorded as filed and, if they do not match, warns you and blocks the step until you review the quarter. If your company meets the exemption conditions, it tells you so that you complete the fourth-quarter 303 section instead of the 390. The result downloads as a PDF and as a file in the tax agency's record layout, ready to import on its site; filing you do with your certificate, or a collaborating gestor does it in your name. The 390 is included in every plan, together with the 303 and the record books that support it.

Frequently asked questions

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