Guide to Spanish Residents Modelo 720 Assets Abroad

If you’re resident in Spain and own assets abroad, you may need to fill out and submit Modelo 720. This form that declares said assets involves a simple procedure and avoids your liability for fines for not declaring assets outside Spain. In this guide, we look at who needs to submit the Modelo 720 as well as other useful information about this form.

What is The Modelo 720?

It’s a form that declares the ownership of assets outside Spain. Think of it as an information document for the Spanish tax authorities. It is not a form to pay tax and by submitting it, you are not necessarily liable for taxes.

Who Has to Submit Modelo 720?

The following people and entities must fill in and submit the form:

• Spanish residents who own assets outside Spain worth over €50,000.
• Spanish businesses that own assets outside Spain worth over €50,000.
• Non-residents or businesses with a permanent base in Spain owning assets outside Spain worth over €50,000.

Thinking of becoming resident in Spain? Find out about long-stay visa options.

What Counts as Assets for Modelo 720?

In the case of this declaration, the following assets are included:

• Holdings such as bonds, stocks and shares, and pension plans.
• Real estate and/or businesses.
• Bank accounts.

Did you know? The 50,000 EUR trigger applies to each of the three asset categories separately, not to your overseas assets as a combined total. If no single category reaches 50,000 EUR at 31 December, you do not have to submit Modelo 720 for that year.

How Often Do You Submit Modelo 720?

All Spanish residents and entities or non-residents or businesses with their base in Spain must submit Modelo 720 when they become resident. You only need to submit the form again if your financial circumstances change (see below).

Is There a Time Period for This Declaration?

Yes, the Modelo 720 should be filled in and submitted between January 1^st and March 31^st. The same time period is open every year.

Need professional tax representation? Find out how we can help you.

What Sort of Changes Do I Need to Declare?

You need to submit a new Modelo 720 if your assets abroad change by over €20,000. For example, you may have an investment that matures. Or you might sell a property.

All these changes, however small, need to be reflected in your new Modelo 720.

How Do I Submit My Modelo 720?

This declaration can only be presented online via the Spanish Tax Authorities website. Read information in English about Modelo 720 here.

At Costaluz Lawyers, we advise using the services of an experienced tax advisor to help you with this declaration and ensure that you present it correctly. Contact us for a free consultation.

The Three Categories of Assets

Modelo 720 does not treat your overseas wealth as one number. It splits it into three separate categories, and each one is assessed on its own:

• Category 1 — bank accounts and deposits held with financial institutions abroad.
• Category 2 — securities, rights, insurance policies and income held or managed abroad, including investment portfolios and defined-contribution pension pots.
• Category 3 — real estate and rights over property located outside Spain, reported at acquisition value rather than current market value.

The 50,000 EUR trigger applies per category, not to the combined total. Review each category independently as at 31 December. If any single category exceeds 50,000 EUR you must file for that category, and you do not report the categories that fall below it. A Spanish tax resident with 40,000 EUR in a UK savings account, 45,000 EUR in a US brokerage account and a 200,000 EUR flat in France is over the threshold only on the real estate category.

Who Counts as a Spanish Tax Resident

The obligation follows tax residency, not nationality. You are a Spanish tax resident if you spend more than 183 days a year in Spain, or if your centre of economic activities is in Spain. Non-residents do not file Modelo 720. Both individuals and companies resident in Spain fall within scope.

How to File: The Practical Steps

Modelo 720 is filed electronically through the Spanish Tax Agency’s online platform, the Sede Electronica de la AEAT. It cannot be filed on paper. You will need a digital certificate or a Cl@ve PIN to identify yourself, and the underlying documentation for each asset: account numbers and balances at 31 December, portfolio valuations, and the acquisition deed and value for any property.

The filing window opens on 1 January and closes on 31 March each year, and it reports on the positions you held at the previous 31 December.

Penalties and the 2022 Court of Justice Ruling

Modelo 720 was introduced in 2012 by Ley 7/2012, and for nearly a decade it carried penalties that could exceed the value of the assets being declared. On 27 January 2022, in Case C-788/19, the Court of Justice of the European Union ruled that the Spanish penalty regime was disproportionate and contrary to EU law. Spain reformed it in March 2022 through Ley 5/2022.

What changed: the regime’s most punitive feature — treating undeclared foreign assets as unjustified capital gains with no statute of limitations — has been removed, and the standard four-year limitation period now applies.

What did not change: the obligation to file remains, late filing still carries surcharges and interest, and unreported foreign income can still be reassessed under the general tax rules. The ruling corrected how the penalties were calibrated; it did not remove the duty to declare.

Reclaiming Penalties Paid Under the Old Regime

If you paid a fine for non-compliance before the 2022 ruling, a refund may be available, and the route depends on what you did at the time. Non-compliance attracted three different types of fine, so the first step is always to establish which one you paid and what action you took in response — whether you appealed, paid without appealing, or had the assets attributed to your income.

Where a fine was paid and not appealed, the route is a claim for the penalty to be declared null and void, or a claim in patrimonial liability against the State. Where an appeal is still awaiting a decision from the tax authorities, that decision is now likely to be favourable. The procedure is complex and varies case by case, so it is worth putting it in the hands of a lawyer who has run one.

Modelo 720 and Modelo 721: Cryptocurrency Is a Separate Form

Cryptocurrency held abroad is not declared on Modelo 720. Since 1 January 2024, Spanish residents holding virtual currencies abroad declare them on Modelo 721, established by Law 11/2021, Royal Decree 249/2023 and Order HFP/886/2023.

The distinction that matters in practice is where the coins are custodied. If your cryptocurrency is held on a Spanish exchange, the exchange reports it and you do not file Modelo 721 for it. Only crypto held on foreign platforms must be declared. The two forms are separate obligations and should not be conflated.

Joint Accounts and Shared Ownership

Each tax resident files on their own share. If both spouses are Spanish tax residents and an account abroad is held jointly on a 50/50 basis, each files their 50% share against their own personal threshold. If the account is held entirely by one spouse, only that spouse files.

Reviewed by María Luisa de Castro, CEO at CostaLuz Lawyers — Updated 2026

This is general information, not definitive legal advice — every case requires individual analysis.