In 2025 Jorge opened a small physiotherapy clinic in Zaragoza as a self-employed professional (autónomo). He took on a physiotherapist as an employee and every month pays a psychologist who works with him on an invoice basis. In December his adviser told him that January was time for "the 190", and Jorge asked us how much he was going to pay and whether he could pay it by direct debit. The answer surprised him: Modelo 190 is not paid. It is an information return and there is no payment with it. What is paid, and what he really had to plan for, are each quarter's withholdings with Modelo 111 and, if something goes wrong, the fine for the 190.
This page explains that difference and how each item is paid. The overall picture of what a self-employed person with staff or collaborators has to file is on the self-employed in Spain page.
What is paid, when and with which form
| Item | Form | Deadline | Is there a payment? |
|---|---|---|---|
| Withholdings for the 1st quarter | 111 | 1 to 20 April | Yes |
| Withholdings for the 2nd quarter | 111 | 1 to 20 July | Yes |
| Withholdings for the 3rd quarter | 111 | 1 to 20 October | Yes |
| Withholdings for the 4th quarter | 111 | 1 to 20 January | Yes |
| Annual summary of withholdings | 190 | 1 to 31 January | No |
| Fine for filing the 190 late or wrongly | Assessment from the AEAT, the tax agency | Whatever the notification states | Yes |
The 190 sets out, recipient by recipient, what you already paid in with the four 111s. If the 111s are paid and add up, the 190 does not add a single euro. If you would like us to check whether your calendar is properly set up, tell us about it in the self-employed form.
The ways of paying the 111s that feed the 190
Direct debit
For quarterly returns, direct debit can be set up from the 1st to the 15th of the filing month, and the charge is made on the last day of the period. It is the route that produces the fewest mistakes, because filing and payment go together and do not depend on someone remembering to go to the bank.
NRC
If you file after the 15th, you pay first at your bank (online or at the counter, if it is a collaborating bank) and obtain a full reference number, the NRC, which you enter when filing. Without a valid NRC there is no payment, even if the return shows as filed.
Account debit or card from the online office
The online office itself allows payment by debit to your account or by card at the banks that accept it, with the same effect as the NRC.
Jorge's figures
His physiotherapist earns €1,800 gross a month and, given her personal circumstances, a withholding rate of 9 % applies to her. The psychologist invoices €1,000 a month, with 15 % withheld.
- Monthly withholding for the employee: €1,800 × 9 % = €162.
- Monthly withholding for the psychologist: €1,000 × 15 % = €150.
- Total per quarter: (€162 + €150) × 3 = €936, which Jorge pays in with each 111.
- Annual total: €936 × 4 = €3,744, which is exactly what the January 190 has to show: €1,944 under the code for employees and €1,800 under the code for professionals.
What is most often forgotten is cash flow. Jorge transfers €850 a month to the psychologist, not €1,000; the remaining €150 are not his, they belong to the tax authorities, and he holds them in his account until the 20th of the month after the quarter. Anyone who spends them thinking they are margin finds themselves in April with a 111 they cannot pay.
What is a business expense and what is not
For Jorge's IRPF (personal income tax), the deductible expense of his business is the psychologist's full invoice, €1,000 a month, and the employee's gross salary, €1,800, plus the employer's Social Security contribution. The withholding is not an added cost and is not deducted separately: it is part of that same expense which, instead of going to the recipient, goes to the tax authorities on their behalf. That is why the 190 does not change Jorge's profit at all. What does change it is a 111 paid with a surcharge, because the surcharge is not a deductible business expense. Another reason to pay each quarter on time.
Why withholdings cannot be deferred
Here is the point that makes the 111 and 190 pair different from almost any other tax. Article 65.2 of the Ley General Tributaria, the General Tax Act, declares debts for withholdings and payments on account non-deferrable, except in the exceptional cases the rules provide for. An application to defer a 111 is normally rejected out of hand, and that rejection leaves the debt as if nothing had been requested. We explain it in debts that cannot be deferred.
The reason is one of substance: that money does not belong to the person withholding it. They deducted it from someone else, who already treats it as paid on account of their own tax. That is why the waiver of a guarantee for debts up to €50,000 in Orden HFP/311/2023, which helps so much with other debts, is of no use here.
One more nuance on the amounts: the withholding tables for employees change with their personal and family situation, and the employer must adjust the rate when it is informed of the change. A withholding that was not adjusted properly is not fixed in the 190; it is fixed in the following payslips.
How the fine for the 190 is paid, if it arrives
If the 190 is filed late or with wrong data, the Agencia Tributaria notifies a penalty decision with its payment slip. The deadline is the one in article 62.2 of the General Tax Act: if the notification arrives between the 1st and the 15th of the month, until the 20th of the following month; if it arrives between the 16th and the last day, until the 5th of the second month. It is paid with the payment document at a collaborating bank or from the online office, with an NRC or by card. Paying it within that period and not appealing gives the right to the 40 % reduction in article 188.3.
Penalties, unlike withholdings, can be deferred, although with such small amounts it is rarely worth doing.
Three payment mistakes that end up showing in the 190
- The certificate you give each recipient (article 108.3 of the IRPF Regulation) and the 190 have to say the same thing. If you put on the certificate a withholding you did not pay in, the recipient will deduct it and the mismatch will surface against you.
- Paying a 111 without filing it is no use: the Agencia Tributaria receives money it does not know where to allocate. Filing and payment go together.
- When you cannot pay a 111, filing it anyway is what makes the difference: without it, on top of the debt, there is a penalty for failing to pay. How the first year works with all these forms is explained in first year as self-employed: the calendar of forms.
The fourth-quarter 111 is filed from 1 to 20 January and the 190 up to the 31st. It is common for someone to set up the direct debit for the 111 on the 14th, file the 190 on the 30th with different amounts and create a mismatch between the two. Close the year's figures first, reconcile them and then file both returns with the same numbers.
Jorge came out of the conversation with a different idea of January: not one more payment, but a check on what he has already paid. If the four 111s are right, the 190 is a formality; if one of them is wrong, the 190 is where it shows. And although the summary carries no amount to pay, not filing it has a cost, as we explain in I forgot to file Modelo 190.