Author:
Miriam Sanchez.
Tax innovations 2025: Compulsory declaration of real titleholders on model 036
February 2025 brings important tax changes for companies, highlighting the mandatory declaration of real titleholders in the model 036. This new measure seeks to reinforce transparency and fight against money laundering, but it can generate some regulatory confusion for those who are not familiar with the process. In this post we explain what this obligation consists of, who it affects and how you can comply with it correctly without complications.
What does it mean to declare the real titleholders?
The figure of the real titleholder refers to the natural person who, directly or indirectly, owns or controls more than 25% of the share capital or voting rights of a company, or who exercises effective control over the company. The new regulations oblige companies to identify and communicate this information through model 036, ensuring that the Tax Agency has updated data.
Who is affected by this obligation?
This statement is not optional and affects:
- Corporations, cooperatives and associations.
- Foundations and other similar legal entities.
The obligation also applies to companies that are already incorporated and must submit this information if they did not do so at the time of their creation or if there have been changes in the ownership structure.
The challenge: avoiding errors due to regulatory confusion
Although the objective of the measure is clear, the regulation can be complex for many companies that do not know the details of the process. Correctly identifying the real titleholders and reflecting this information on model 036 can be a challenge, especially for small and medium-sized businesses (SMEs).
Common mistakes such as not identifying the correct real titleholder or not updating the information on time can result in significant financial penalties.
How to comply with the new obligation in a simple way?
This is where specialized tax advice can make a difference:
- Data review and update: Check if your company has already declared the real titleholders and update the information if necessary.
- Filing model 036: Make sure you complete the declaration correctly, avoiding errors that may result in penalties.
- Integration with tools such as Holded: Facilitates document management and tax compliance with an ERP that centralizes and automates key processes.
The 2025 tax changes represent a further step towards transparency, but they also pose a challenge for companies. Not facing this obligation properly can be costly. Cigarrán Abogados accompanies you in this process, helping you to interpret the regulations and filing the tax return correctly.
¿Do you need help? At Cigarrán Abogados we can help you (+34) 91.355.85.15
