Prepare and generate the Model 238 export in the VRMS
Model 238 in Spain is a mandatory annual informative return for certain digital platform operators. Its purpose is to provide the Spanish State Tax Administration Agency (AEAT) with detailed information on economic transactions carried out through these platforms, particularly in the tourist rental sector. This model replaces the former Model 179 and, unlike it, the obligation to report lies with the digital platforms rather than with property owners, in application of the European DAC7 Directive to strengthen tax control.
Avantio has developed the Model 238 export in XML format, allowing you to extract directly from the VRMS the data required to submit the return.
This export is intended for Property Managers whose registered office is in Spain and who are required to submit Model 238. If this applies to you, the VRMS helps you prepare the file, although the ultimate responsibility for submission to the Tax Agency remains yours.
Please note the timeline: the Model 238 XML file cannot be uploaded to the Tax Agency website until 2026, to report data corresponding to the 2025 financial year. Nevertheless, the export functionality, together with the newly required fields, will be deployed in production before the end of the year so that you can start preparing all the information.
Complete the tax details of the company, owners and properties
To generate the XML file, the VRMS uses information from your company details, property owners and accommodations. Some fields are mandatory and have specific validations; if any required data is missing or does not meet the format, the export will display errors based on this validation table.
Complete the tax details of your company details
In the company details section, you must review and complete the following fields:
Field | Mandatory | Format / value | Validation |
Name | Yes | Max. 200 characters | The name is mandatory and cannot exceed 200 characters. |
Tax ID (CIF) | Yes | Max. 200 characters | The CIF is mandatory and cannot exceed 200 characters. |
IN | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Intra-community VAT | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Address type | Yes | OECD301, OECD302, OECD303, OECD304 or OECD305 | Address type is mandatory. |
Country | Yes | ISO3166 code | Country of residence is mandatory. |
Street | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Number | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Door | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Postcode | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Province | No | Max. 200 characters | If completed, it must be verified. |
City | Yes | Max. 200 characters | City is mandatory and must be verified. |
Review the owner’s identification and birth details
Each owner record must contain sufficient identification and address information so that the system can include it in Model 238. The fields and validations are as follows:
Field | Mandatory | Format / value | Validation |
NIF / TIN | Yes | Max. 200 characters | Document number is mandatory and cannot exceed 200 characters. |
First name | Yes | Max. 200 characters | Mandatory and cannot exceed 200 characters. |
Surname(s) | Yes | Max. 200 characters (combined) | Mandatory and cannot exceed 200 characters. |
IN | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Intra-community VAT | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Address type | Yes | OECD301, OECD302, OECD303, OECD304 or OECD305 | Mandatory. |
Country | Yes | ISO3166 code | Country of residence is mandatory. |
Street | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Number | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Door | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Postcode | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Province | No | Max. 200 characters | If completed, it must be verified. |
City | Yes | Max. 200 characters | Mandatory and must be verified. |
Date of birth | Yes | Date | Mandatory. |
City of birth | Yes | Max. 200 characters | Mandatory and must be verified. |
Province of birth | No | Max. 200 characters | If completed, it must be verified. |
Country of birth | Yes | ISO3166 code | Mandatory. |
IBAN | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Account holder | Yes, if IBAN is completed | Max. 200 characters | Mandatory if IBAN is provided. |
GVS jurisdiction | Yes, if owner model is GVS | ISO3166 code | Mandatory for GVS model. |
GVS reference | Yes, if owner model is GVS | Max. 200 characters | Mandatory for GVS model. |
Verify the property address details
Each accommodation record also uses several address fields for Model 238:
Field | Mandatory | Format / value | Validation |
Address type | Yes | OECD301, OECD302, OECD303, OECD304 or OECD305 | Mandatory. |
Country | Yes | ISO3166 code | Mandatory. |
Street | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Number | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Door | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Postcode | No | Max. 200 characters | If completed, it cannot exceed 200 characters. |
Province | No | Max. 200 characters | If completed, it must be verified. |
City | Yes | Max. 200 characters | Mandatory and must be verified. |
Cadastral reference | Yes | Max. 200 characters | Mandatory and cannot exceed 200 characters. |
Identify the new fields enabled in the VRMS
To support Model 238, additional fields have been enabled in different sections of the VRMS. These fields allow you to complete the information required by the AEAT under DAC7.
Section | Field | Details |
Property record | Address type | Values: Residential, Commercial, Registered office, Not specified. |
Owner record | Identification type | Values: Standard, GVS. Selecting GVS displays additional fields. |
Owner record | Document number | Free field for additional identification information. |
Owner record | City, province and country of birth | Specific birth data fields. |
Owner record | Address type | Residential, Commercial, Registered office, Not specified. |
Owner record | Number, block or door, floor or door | Detailed address fields. |
Company details | Document number | Free field for additional company information. |
Company details | Address type | Residential, Commercial, Registered office, Not specified. |
Before launching the export, it is important to review these records and complete all mandatory fields to avoid errors.
Generate the Model 238 XML file from the VRMS
Once company, owner and property data are complete, you can launch the export from the VRMS export module.
Follow these steps:
Go to Exports → DAC7. You will see two sections: New export and Completed exports.
In New export, use the available filters to narrow down the information to include.
Click Export. The system will generate the file and add it to Completed exports.
Download the Model 238 XML file.
Access the Tax Agency intranet enabled for Model 238 and upload the XML file.
Available filters in New export:
Filter | Options |
Year | List of available years. |
Company | List of companies configured in the VRMS. |
Status | Pre-booking, Confirmed, Paid, Guarantee, Cancelled. |
Portal | Portal list, “No portal assigned” and “Web bookings”. |
Owner | List of owners. |
Export type | Draft*, Normal. |
If errors are detected, they will be displayed according to the validation table. You must correct the data and repeat the export.
If the submission type is Draft*, submitting the XML will not register any data with the Tax Agency. This option is intended for error detection before final submission and is recommended prior to filing the definitive XML.
Review quarterly DAC7 activity and amount information
Model 238 requires activity information to be grouped by quarters. The XML generated by the VRMS includes key concepts populated from booking and settlement data.
XML concept | Description | VRMS source |
Consideration | Net compensation paid to the seller after fees, commissions or taxes withheld. | Owner settlement payments. |
Fees | Commissions, deposits, charges and similar amounts retained by the platform operator. | Total booking amount minus owner payment. |
Number of activities | Number of activities carried out in the quarter. | Number of nights sold. |
Taxes | Taxes collected quarterly by the platform operator. | VAT on the intermediation contract. |
Example of DAC7 calculation for a transaction
The document includes an example for a single transaction in a quarter, subject to 21% VAT.
Sale value: €1,000
Platform commission: €100
Both subject to 21% VAT
Reported values:
Quarterly consideration: €1,000 + €210 VAT − €100 − €21 VAT = €1,089
Number of activities: 1
Fees: €100
Taxes: €21
Equivalent VRMS example:
Total booking amount: €1,210 (VAT included).
Portal commission: €10.
Agency commission: 20% (VAT included) on rental amount minus portal commission.
Quarterly amounts:
Consideration: €1,210 − ((€1,210 − €10) × 0.2) = €970
Fees: €1,210 − €970 = €240
Taxes: (€240 / 1.21) × 0.21 = €41.65
These calculations are performed quarterly for all bookings included in the export, following Model 238 logic.
Manage exclusions and relevant activities in DAC7 calculations
The VRMS includes options to control what information is sent and how it is calculated.
You can exclude properties or individual bookings from Model 238 at both accommodation and booking level. You can also customise the amount considered for Model 238 within each booking if alignment with specific tax criteria is required.
Only bookings with completed owner settlements are considered relevant activities. If a booking is not included in an owner settlement, it will not be included in the XML.
If a booking is missing from the XML, check that a completed owner settlement exists and that neither the property nor the booking is marked as excluded.
Before completing the process, ensure all mandatory fields are updated, settlements reviewed and the XML generated with the correct export type. This will leave the file ready for upload to the Tax Agency’s electronic office when the Model 238 (DAC7) filing period opens.
Frequently asked questions
What information is included in the Model 238 (DAC7) export generated from the VRMS?
What information is included in the Model 238 (DAC7) export generated from the VRMS?
The Model 238 export generated from the VRMS creates an XML file containing the tax details of your company, property owners and accommodations, together with the quarterly activity information required under DAC7: net consideration payable to the owner, commissions and other amounts withheld, number of activities, and taxes charged per quarter. Only bookings considered relevant activities according to the system’s criteria are included.
Who should use the Model 238 export in the VRMS to submit the return to the Tax Agency?
Who should use the Model 238 export in the VRMS to submit the return to the Tax Agency?
This functionality is intended for Property Managers whose registered office is in Spain and who, due to the nature of their activity, are required to submit Model 238 to the Spanish Tax Agency. The VRMS facilitates generation of the XML file, but responsibility for reviewing the information and submitting the return remains with the platform operator.
How do you generate and download the Model 238 XML file from the VRMS?
How do you generate and download the Model 238 XML file from the VRMS?
Go to Exports → DAC7, open New export, select the filters for year, company, status, portal, owner and export type, and click Export. Then, under Completed exports, you can download the generated XML file and upload it to the Tax Agency intranet enabled for Model 238.
What happens if mandatory data is missing or errors are detected when exporting Model 238 from the VRMS?
What happens if mandatory data is missing or errors are detected when exporting Model 238 from the VRMS?
If the system detects that mandatory data is missing or that a field does not meet validation requirements—such as unverified country or city, incomplete dates of birth, or address fields exceeding the maximum length—it will display errors in line with the validation table. In this case, you must correct the information in the company, owner or accommodation records and repeat the export until the file is generated without issues.
How are consideration, commissions and taxes for your bookings calculated in the quarterly DAC7 information of Model 238?
How are consideration, commissions and taxes for your bookings calculated in the quarterly DAC7 information of Model 238?
Consideration is the net compensation received by the owner after deducting fees, commissions and taxes withheld by the platform. Commissions and other withheld amounts (Fees) are calculated as the difference between the total booking amount and the payment made to the owner. The number of activities is based on nights sold, and taxes (Taxes) are taken from the VAT on the intermediation contract. The document includes a detailed example using a €1,210 booking, portal and agency commissions, and the resulting calculation of consideration, fees and taxes.