Jorge is a self-employed sworn translator in Granada and works alone, with no employees. In March a job came in that was too big for him and he subcontracted part of it to a colleague, also self-employed, who invoiced him 900 € for her share. In May he paid 300 € to a print shop for binding some documents, and in June he hired a proofreader who lives in Lisbon. At the end of the quarter he wondered whether all that meant he had to file Modelo 111, a form he had never opened because, as he put it, «I don't have any workers».
The answer is that yes, he did have to file it, but only because of one of those three invoices. And understanding why is the best way to know whether it applies to you.
The obligation does not come from having employees
The 111 is filed by anyone who, in the course of a business or professional activity, pays income that is subject to withholding. The two conditions go together. The first is the status of the payer: a businessperson, a professional, a company, a joint ownership (comunidad de bienes) or another entity. A private individual paying a lawyer for their divorce does not withhold; the same individual, paying the same lawyer for a matter relating to their business, does. The second is the nature of what is paid: salaries, invoices for professional activities, courses and lectures, and certain other income the regulations list, such as some prizes.
Not having workers does not exempt you. A single invoice from a professional in the whole year is enough for that quarter to have its 111.
Jorge's three invoices, one by one
- The fellow translator. She is a professional and an individual, her activity is in the professional activities section of the Impuesto sobre Actividades Económicas (the business activities tax register), and Jorge pays her within his own activity. There is 15 % withholding: 135 €. If she had started her activity that year or in the two before, and had told him so in writing, the rate would be 7 %: 63 €. That invoice means the first-quarter 111 has to be filed.
- The print shop. This is a business activity, not a professional one. Except in specific cases the regulations list for some activities taxed under the module system, invoices from businesses carry no withholding. No withholding, nothing to declare on the 111.
- The Lisbon proofreader. He is non-resident. What he is paid does not go on the 111, which is only for resident recipients: if anything had to be withheld, it would be done on Modelo 216, and the double tax treaty often brings that withholding down to zero. But that is a separate check, made with his certificate of residence, not a conclusion that can be taken for granted.
A table to check it in two minutes
| You pay… | Do you withhold? | Does it go on the 111? |
|---|---|---|
| An employee | Yes, according to the tables and their personal situation | Yes |
| A professional who is an individual (lawyer, architect, designer, translator) | Yes, 15 %, or 7 % when starting out | Yes |
| Someone giving a course or a lecture | Yes, 15 % | Yes |
| A businessperson who is an individual (plumber, print shop, workshop) | Generally not | No, except in listed cases |
| A company providing you with professional services | Not on this Modelo | No |
| A professional resident outside Spain | Checked against the treaty | No; where applicable, Modelo 216 |
| Anyone, when you pay as a private individual | No | No |
If you still have doubts about a particular invoice after looking at the table, describe it in the self-employed form and we will tell you whether it carries withholding, how much, and on which Modelo.
The 7 %: who can ask for it and what paper backs it up
The reduced 7 % rate exists for professionals who are starting out: it applies in the year the activity begins and in the following two, provided they had not carried it on in the year before starting. But it is not decided by the payer but by the person being paid, and they have to say so in writing. Whoever withholds must keep that signed statement. Applying 7 % without that paper is one of the mistakes that generates the most corrections on the 111, because the difference ends up being paid by the payer.
In Jorge's case, his colleague had been practising for eight years, so 15 %. The invoice should have arrived with a base of 900 €, 189 € of VAT and 135 € of withholding, with a net total of 954 €. Jorge pays her 954 € and pays over 135 € with the first-quarter 111, before 20 April.
Three situations often confused with the 111
Renting business premises. If you pay rent on premises for your activity, you also withhold, but not on the 111: that withholding has its own Modelo, the 115. They are two separate returns on the same calendar, and it is common for someone filing one to forget the other.
Payments to partners or relatives. If your partner helps you in the business and you pay them something, the first thing is to know on what basis: a salary with registration in Social Security carries withholding and goes on the 111; help without a contract has no clear tax treatment and is a different problem, best solved before paying rather than after.
Invoices from platforms and software. Subscriptions, payment gateway fees and services from foreign companies carry no withholding on the 111. An invoice being for services is not enough: it has to be from a resident professional who is an individual, or for one of the kinds of income the regulations list.
What almost nobody tells you: the census and the empty quarters
To file the 111 you have to appear in the census (the tax register of your obligations) with the obligation to withhold, and that is notified on Modelo 036. Since February 2025 the 037 no longer exists, so any registration, change or removal of this obligation goes through the 036. If you never ticked that box because you had no employees, the first step is to tick it.
The second part of the question is the one that tends to generate letters. The income tax (IRPF) regulations only require a nil return when, having paid income subject to withholding, nothing was withheld because of the amount. If in a quarter you pay no professional and no worker, strictly speaking there is nothing to declare. But the census is what the Administration looks at: as long as it says you have the obligation, it will expect a 111 every quarter and send requests (requerimientos) if one does not arrive. That is why, when professionals' invoices are occasional, you have to make a considered choice between removing the obligation on the 036 or filing the empty quarters at zero. Both options are correct; what does not work is doing neither.
If a professional sends you an invoice without the withholding line, the obligation to withhold is still yours. The right thing is to ask for a corrected invoice or, if you have already paid it in full, to be clear that Hacienda can claim from you what you did not withhold. An agreement between the parties does not change an obligation the law imposes.
And in January, the summary
Anyone who files a 111 during the year also files, from 1 to 31 January of the following year, Modelo 190: the list of recipients with what each one was paid and what was withheld from them. For Jorge, a single line with his colleague, 900 € and 135 €. It is little work, but it is compulsory, and it is what lets his colleague see the withholding in her tax data. How this fits with the other returns of the first year is in the calendar of returns for your first year as an autónomo, and the overall picture of the two most common kinds of withholding in the guide to Modelos 111 and 115.