Spanish process splits compliance across three separate filings.
The AEAT shows models 240 and 241 available from 30 April 2026 and model 242 from 1 July 2026. For first-cycle periods ending before 31 March 2025, the BOE order sets special initial windows rather than relying only on the normal 15-month/18-month framework.
Members can view a Spain Pillar Two Filing Checklist at: Spain Pillar Two Filing Checklist PDF.
This identifies the Spanish constituent entities, the filing role for the GIR, and the substitute taxpayer arrangement for model 242 where relevant
Spain’s GIR-DAC9 information return. It keeps the OECD GLOBE body but adds a Spanish presentation wrapper and local validation rules.
The self-assessment and payment return for the complementary tax. This is separate from both the GIR and the model 240 form.
The functions of the three key Spanish forms are:
–Model 240 is the notification. It tells AEAT which Spanish constituent entities are covered, who is acting as the GIR filing entity, whether the Spanish case is a central filing or local filing scenario, and who acts as substitute taxpayer for model 242 if that mechanism applies.
–Model 241 is the information return. Spain describes it as the GIR/DAC9 filing and expressly says it follows the OECD GIR structure for the same GLOBE Body, but with a Spanish header and local controls.
–Model 242 is the self-assessed top-up tax return. It is filed separately from the GIR and must line up with the taxpayer or substitute-taxpayer position established in the Spanish compliance chain.
| Form | General timing | First-cycle / transition point | Practical note |
|---|---|---|---|
| Model 240 | Before the last day of month 12 after the end of the reporting period. | For periods ending before 31 March 2025: 30 April 2026 to 30 June 2026. | One model 240 can cover all Spanish constituent entities in the group. |
| Model 241 | Before the last day of month 15 after the period end. | For the first time a group is in GloBE: within the two months before month 18 after period end. For periods ending before 31 March 2025: 30 April 2026 to 30 June 2026. | Spain allows both service-web and form-based submission routes. |
| Model 242 | Within the 25 calendar days following month 15 after the period end. | For the first filing cycle, the BOE order says it cannot be filed before 30 June 2026, and the filing window then runs during the following 25 calendar days. | AEAT’s web page shows model 242 becoming available from 1 July 2026. |
Spain requires electronic filing through AEAT. The AEAT pages for models 240 and 242 say the filing can be made with a recognized certificate by:
-the taxpayer itself,
-a duly authorized representative, or
-an AEAT-authorized intermediary.
AEAT also notes that a specific power-of-attorney can be granted for these models, in addition to the general social-collaboration or representation frameworks.
For model 241, Spain has four live pathways:
-Filing through a web-service client,
-Submission via form: New and supplementary forms
-Submission via form: Modifications and cancellations
-Querying already submitted returns.
-AEAT publishes a developer page for model 241 with the national XSD, note on the XSD, OECD GIR guide, and web-service materials.
-There is a separate Spanish presentation layer on top of the OECD GIR body.
-The service-web route and the form route ultimately call the same validation logic.
-The Spanish return set works only if the filing role, substitute-taxpayer logic and model references line up across all three forms.
Model 240 carries key coordination data that affects the later filings.
-identifies the declarant and the contact person,
-can cover all Spanish constituent entities in one communication,
-lists the Spanish constituent entities included,
-identifies the UPE and, if relevant, multiple UPEs under the Spanish rules,
-identifies the filing role for model 241 as UPE/designated filer/local designated entity/other constituent entity,
-records the foreign filing reference if a GIR has already been filed elsewhere, and
-identifies the substitute taxpayer for model 242 where Spain’s substitute-taxpayer mechanism applies.
A local nuance is that if the filing role corresponds to a local filing scenario, Spain says the Spanish model 241 contains only the jurisdictions over which Spain has taxing rights. That means the model 240 role choice is not just administrative metadata; it affects the expected scope of the Spanish GIR filing.
Model 241 is the most technical of the three Spanish filings. Spain keeps the OECD GIR content but wraps it in a national presentation structure and applies local filing and validation rules.
AEAT offers three ways to send the model 241 form:
The form manual says all three modalities use the same service web underneath, so the validation logic is effectively shared.
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