Modelo 720 and 721 in Spain 2026: assets held abroad

Who has to file the modelo 720 in Spain?

The obligation falls on Spanish tax residents who are holders or beneficial owners of assets and rights located abroad above the legal threshold. In the accounts category it also extends to representatives, authorised signatories, beneficiaries and people with power of disposal; in the securities category it additionally reaches the policyholders of life insurance and the beneficiaries of temporary or lifetime annuities; for property it is limited to holders and beneficial owners. It does not depend on your nationality or on the country where the assets sit: it depends on where you had your tax residence in the year being reported. It also reaches permanent establishments and entities without legal personality under article 35.4 of the General Tax Act (Ley General Tributaria).

You are a Spanish tax resident when you spend more than 183 days of the calendar year on Spanish territory, counting sporadic absences unless you can evidence tax residence in another country, or when the main centre or base of your activities or economic interests is in Spain. Residence is also presumed if your spouse, not legally separated, and your dependent minor children habitually live in Spain, although this presumption can be rebutted with evidence.

Residence is measured for the year the information refers to, not the year in which you file. Someone who moves abroad halfway through the year is still obliged if they have to file Spanish income tax for that year. Heirs and legatees become obliged from the moment there is tacit or express acceptance of the estate. In the Basque Country and Navarre the obligation is governed by the corresponding regional or state rules.

Is the €50,000 threshold per category or for everything you own abroad?

The €50,000 threshold applies category by category, independently, and not to your whole estate located abroad. This is the most widespread error online and the one that triggers the most unnecessary filings. The three categories of the modelo 720 are: accounts with financial institutions; securities, rights, insurance policies and annuities; and property and rights over property. Virtual currencies form a separate fourth category that is declared on the modelo 721.

In the accounts category two figures are compared: the sum of the balances at 31 December and the sum of the average balances of the last quarter. If either one is exceeded, every account has to be declared. The securities category adds together foreign shares, funds and ETFs, the net asset value of collective investment undertakings, the surrender value of life policies and the capitalisation value of annuities. Property is measured on its acquisition value.

Once a category is over the threshold, everything inside it has to be declared, including small items: the forgotten account with €300 in it goes in just the same. Negative balances, such as an overdrawn credit account, are netted against positive ones when working out whether the limit has been crossed. And accounts you hold in your own name are added to those where you are merely an authorised signatory, unless the account itself is exempt for its holder — for example because an institution domiciled in Spain has to report it. Another joint holder filing their own modelo 720 does not exempt the authorised signatory.

Do I need to file the modelo 720 every year?

No. Once you have declared a category for the first time, you only have to declare it again if its value rises by more than €20,000 against the value that determined the last return filed for that category, or if during the year a holding or the status that triggered the obligation is cancelled, extinguished or lost. Outside those two situations, nothing is filed for that category.

The comparison is made against the last return actually filed for that specific category, not against the immediately preceding year. If you declared accounts in 2023 and have not been obliged since, the point of comparison is still the value declared in 2023. Keep a copy of every return you file: without it there is no way of knowing whether you have crossed the repeat-filing threshold.

Cancellation or extinction always triggers a filing, even if there has been no increase and even if the value is below the threshold. You report the balance or value on the date you stopped holding that status and, for property, the transfer value and date as well. The same applies when an authorisation over an account is revoked. By contrast, someone who was never obliged for that category does not have to report the cancellation.

Modelo 720 deadline: when and how to file

The window runs from 1 January to 31 March of the year following the tax year being reported, with no extension. The campaign for the 2025 tax year closed on 31 March 2026; the 2026 tax year will be filed between 1 January and 31 March 2027. The modelo 721 for virtual currencies follows exactly the same calendar. It is worth noting that the 720 falls due before the income tax and wealth tax campaign.

Filing is online only: there is no paper form and no filing at an office, and the order that approved the form provides no alternative. You log in with an accepted electronic certificate, an electronic DNI or, in the current practice of the Agencia Tributaria's online office, with Cl@ve. Filing by any means other than electronically when you are obliged to file electronically is in itself a serious tax infringement, with its own penalty.

If the filing is accepted, the system returns the validated data with a sixteen-character secure verification code, the date and the time; you are required to keep that receipt. If there is a technical incident attributable to the system, the order allows filing during the three calendar days following the end of the window. And if the Agencia Tributaria issues a request to correct defects, you have ten days from the day after notification; if you do not respond, the obligation is treated as unfulfilled.

Modelo 721: crypto held outside Spain

Virtual currencies are no longer declared on the modelo 720: since the 2023 tax year they go on the modelo 721, approved by Orden HFP/886/2023, with its own independent €50,000 threshold. The first 721 campaign was filed between 1 January and 31 March 2024, covering the 2023 tax year. Any content telling you to declare crypto on the 720 is out of date.

The 721 covers virtual currencies held abroad by third parties who safeguard the private cryptographic keys, which in practice means balances on exchanges and in custodial wallets. Self-custody in a cold wallet whose keys only you control falls outside the modelo 721, without prejudice to those assets being taxed under income tax when they are disposed of and counting towards wealth tax.

Valuation is done at 31 December in euros, taking the price quoted on the main trading platforms or price-tracking sites and, failing that, a reasonable estimate of market value; you have to state the price source you used and also report the balances in units of each virtual currency. The €20,000 repeat-filing rule and the cancellation rule work exactly as they do on the 720. Forms 172 and 173 are filed by service providers, not by individuals: that is how the Agencia Tributaria already knows about balances held on Spanish platforms.

Does the 150% modelo 720 fine still exist?

No. The proportional fine of 150% has been repealed since 11 March 2022 and cannot be applied to any regularisation today. It was repealed by Ley 5/2022, of 9 March, whose sole repealing provision removed the first and second additional provisions of Ley 7/2012, which is where that penalty lived. No rule in force today provides for a proportional fine based on the value of undeclared assets.

The change originates in the judgment of the Court of Justice of the European Union of 27 January 2022, case C-788/19, European Commission v Kingdom of Spain, which held the legal regime attached to the modelo 720 incompatible with the free movement of capital. Ley 5/2022 gave effect to that judgment on three fronts: it removed the specific penalty regime of the eighteenth additional provision of the General Tax Act, rewrote article 39 of the income tax act to remove the open-ended assessment period, and deleted the equivalent rule in corporate income tax.

The practical consequence is twofold. First, the general four-year limitation period now applies to assets held abroad as well. Second, evidence that the assets were acquired in a period already time-barred can once again be raised against the tax authority: unjustified capital gains are included in the general taxable base of the period in which they are discovered unless you can prove ownership predating the limitation period. That is precisely what the open-ended regime used to prevent.

What are the penalties for not filing the modelo 720 today?

The general regime of the General Tax Act now applies: failing to file an information return on time is penalised at €20 for each item or set of items of data, with a minimum of €300 and a maximum of €20,000, under article 198.1. It is a minor infringement with no direct financial loss to the Treasury, because the form carries no tax due. It is nothing like the order of magnitude of the repealed regime.

If the return is filed late but voluntarily, without a prior request from the tax authority, article 198.2 sets different amounts: half, that is €10 per item of data, with a minimum of €150 and a maximum of €10,000. Technically this is not a 50% reduction but a separate statutory amount for voluntary late filing. The only reduction properly so called that applies here is the 40% for prompt payment without appealing; the 30% for agreement does not apply to these infringements.

If the return is filed incomplete, inaccurate or with false data, article 199 comes into play: for monetary data the fine can reach 2% of the amount not declared or declared incorrectly, with a minimum of €500, and for non-monetary data it is set at €200 per item omitted or inaccurate, depending on the nature of the data. Repeat offending increases the amount. The Agencia Tributaria also makes clear that these penalties apply independently for each of the three reporting obligations.

How each category is valued and which exchange rate applies

Each category has its own valuation rule, and everything is converted into euros using the exchange rate in force at 31 December of the year being reported. That date is the common reference point for the whole form and it coincides with the wealth tax charging date, which lets you reconcile both returns from the same bank paperwork and avoid giving two different figures for the same asset on two forms the tax authority cross-checks.

For accounts you have to report two separate figures, both compulsory: the balance at 31 December and the average balance of the last quarter of the year. For securities the valuation rules of Ley 19/1991 on wealth tax apply, and the Agencia Tributaria also accepts the quoted price at 31 December for holdings traded on foreign markets. For life policies you declare the surrender value and, where there is no right of full surrender, the mathematical provision; for temporary or lifetime annuities, the capitalisation value.

For property the figure is the acquisition value, including the costs inherent to the purchase and the taxes paid, not the market value or a foreign cadastral value. Timeshares and rights of periodic use, and bare ownership and usufruct rights, are valued at 31 December under the rules of Ley 19/1991. Neither the order approving the form nor the Agencia Tributaria's FAQs designate a specific official source for exchange rates, so it is sensible to document the source you use and keep it consistent from year to year.

Joint accounts, community property and beneficial ownership

Where an asset is jointly held, the threshold is measured on the total balance or value of the asset, without apportioning it between the holders. It is not divided by the number of joint holders: if the account exceeds €50,000, every resident joint holder is obliged, each through their own return. This is the second most frequent source of errors after the per-category threshold, and it produces double penalties when a couple assumes that one filing covers both of them.

What you enter is the total balance or value of the asset, together with the percentage of participation corresponding to you as the filer. The example the Agencia Tributaria itself uses is clear: for an account of €150,000 with a 30% participation, you declare €150,000 and state 30%. You never declare €45,000. The same logic applies to a portfolio of securities shared between siblings after an inheritance.

If an asset forms part of community property but is formally in the name of one spouse only, both declare: the formal holder with the holder code at 100% and the other spouse with the code for other forms of beneficial ownership at 50%. One little-known asymmetry is worth remembering: being an authorised signatory creates an obligation for accounts but not for securities. And if you are the holder of an account you do not also declare it as an authorised signatory.

What you do not have to declare on the modelo 720

You do not declare what the Agencia Tributaria already knows through another channel, nor what falls outside the scope of the form. Before preparing the return it is worth going through the exemptions one by one, because over-declaring also creates work, cost and the risk of an error in the data, and every inaccurate item of data is penalisable in itself even if the asset did not have to appear at all.

Exempt from reporting are foreign securities and funds deposited or marketed by a Spanish institution obliged to report to the tax authority, policies with a foreign insurer operating in Spain through a representative obliged to report, and assets recorded individually in the accounts of businesses and companies. The golden rule is simple: what already reaches the tax authority by another route is not duplicated on the 720.

Outside the scope of the form are stock options, physical gold, jewellery, works of art, vehicles, boats and cash, as well as private loans to third parties not represented by securities. Foreign ETFs and unit-linked policies, both widely sold to British expats, are inside it. Vested rights in a foreign pension scheme are not reported until the contingency occurs. The fact that an asset does not go on the 720 does not mean it is ignored for wealth tax.

Your first year as a Spanish tax resident

If you acquire Spanish tax residence in a given year, you file the modelo 720 for that whole year between 1 January and 31 March of the following year. There is no grace period and no exempt first year, and the belief that there is remains one of the most repeated myths among new arrivals on the Costa Blanca.

The reason is that Spain does not operate split-year treatment: residence is determined by the complete calendar year. Someone who moves to Torrevieja or Alicante in March and stays more than 183 days is a tax resident for that entire year, and their first return reports the position at 31 December. Hence a counter-intuitive corollary: if you sell your former home in October and no longer own it at 31 December, that category may end up below the threshold.

The special regime for posted workers under article 93 of the income tax act, known as the Beckham law, is the relevant exception: the Agencia Tributaria confirms that people covered by it are not obliged to file the modelo 720, and for wealth tax they are taxed on a real basis only, that is on assets located in Spain. The regime lasts for the tax period of the change of residence and the five following ones.

Three qualifications are worth keeping in mind. The exclusion does not extend to a spouse or to children who are not covered by the regime, who may well be obliged. When the regime ends, or you opt out or are excluded from it, the obligation returns in full. And the first year back under the ordinary regime means declaring everything you hold outside Spain, not only what you acquired afterwards.

UK pensions, ISAs and other expat cases on the Costa Blanca

The UK state pension, ISAs, SIPPs, accounts back home and property inherited outside Spain account for most of the questions in Torrevieja, Orihuela Costa, Guardamar and Jávea. Brexit changed nothing about this form: the obligation depends on tax residence in Spain, not on nationality or on whether your home country belongs to the European Union. What did change, and change a great deal, is the cost of forgetting, after the 2022 judgment.

The British ISA has no tax-free equivalent in Spain: a stocks and shares ISA is a portfolio of foreign securities and counts in the securities category, while a cash ISA works as a deposit and counts in the accounts category. Its returns are also taxable under Spanish income tax even though they are tax-free in the United Kingdom. It is by some distance the most expensive mistake among British residents on the Costa Blanca.

With a SIPP the answer depends on the contract. Vested rights are not reported until the contingency occurs, but if the product allows full surrender on terms analogous to a life policy, the tax authority's doctrine is that the surrender value does have to be reported; and once it is received as an annuity derived from the payment of a capital sum, that annuity is reported. A state pension already in payment is not in itself a reportable asset on the 720, even though it is taxable on your Spanish income tax return.

Russian, Ukrainian and Kazakh buyers should know that the form does not distinguish by country: accounts in Russia, Kazakhstan, the Emirates or Cyprus count just the same, and a balance frozen by sanctions is still owned by the filer, so illiquidity is no excuse for not reporting. In inheritances, heirs are obliged from acceptance, and if a surviving spouse keeps the usufruct and the children the bare ownership, each declares their own right separately. For Americans, FBAR and FATCA are obligations independent of the 720.

The modelo 720 alongside income tax, modelo 714 and the tax on large fortunes

The modelo 720 generates no payment: it is an information return with no tax due. What can generate tax are three other, separate obligations that are worth reconciling using the same data and the same reference date, 31 December. Declaring on the 720 and forgetting income tax or wealth tax is an inconsistency the tax authority spots easily.

Income tax catches the income those assets produce: interest, dividends, rent from a property abroad, capital gains on its sale and any pensions Spain is entitled to tax. To avoid double taxation you apply the relief in article 80 of the income tax act, which lets you deduct the lower of two amounts: the analogous tax actually paid abroad, or the average effective rate applied to the part of the taxable base taxed abroad.

Wealth Tax (Impuesto sobre el Patrimonio) is filed on modelo 714, and for the 2025 tax year the window ran from 8 April to 30 June 2026, the same as the income tax campaign. The state exempt amount is €700,000, but each region can set its own: the Comunitat Valenciana set it generally at €1,000,000 for the 2025 tax year, an amount that does not apply in Madrid, Andalusia or Catalonia. Watch out for a common trap: you must file if the value of your assets exceeds €2,000,000, even if the tax due is zero.

Above that sits the Temporary Solidarity Tax on Large Fortunes (Impuesto Temporal de Solidaridad de las Grandes Fortunas), a state tax on net wealth above €3,000,000 at rates of 1.7%, 2.1% and 3.5% depending on the band, with a €700,000 exempt amount extended to residents and non-residents by Real Decreto-ley 8/2023. It remains in force until wealth taxation is reviewed. It is filed on modelo 718 from 1 to 31 July of the year following the charging date, but only by those whose tax works out as payable: with the €700,000 exempt amount and the first band taxed at 0%, that happens from around €3,700,000 of net wealth.

Common valuation and currency conversion mistakes

The most expensive mistake is measuring the threshold against each joint holder's share instead of against the total value of the asset, because it leaves one spouse's entire return unfiled. Next, by frequency, come forgetting the average fourth-quarter balance on accounts, using market value instead of acquisition value for property, and leaving out the small account back home, which does count towards the threshold.

For conversion into euros you apply the exchange rate in force at 31 December of the year being reported, not the average rate for the year and not the rate on the date the account was opened or the asset bought. Since the rules do not designate a specific official source, the prudent course is to record the source you used, apply it consistently to every asset in the same year and keep the calculation with the rest of your supporting paperwork.

There is one detail that catches many British residents out: for accounts and securities, movements in the exchange rate do count towards deciding whether the category has risen by more than €20,000 and has to be declared again, whereas for property they do not, because the acquisition value is a historic figure. A pound that strengthens against the euro can force you to re-declare a portfolio without your having bought or sold anything.

Finally, it is time to abandon the idea that these assets are invisible. Spain receives financial account information through the automatic exchange mechanisms and, more recently, from digital platforms and crypto-asset operators as well. The relevant question is no longer whether the tax authority knows, but whether it is better to regularise voluntarily before a formal request: voluntary late filing halves the penalty and, combined with putting your income tax right, limits the cost to the surcharge for late self-assessment.