Note: This article reflects 2026 rules and is undergoing final review by María Luisa de Castro (ICA Cádiz nº 2745). Specific figures and thresholds should be confirmed for your case — book a consultation or email marialuisa@costaluzlawyers.es.
Modelo 720 is the informative declaration Spanish tax residents file to disclose foreign-held assets above threshold. After the 2022 ECJ ruling against Spain, the penalty regime was rewritten — but the filing obligation remains. Miss it and AEAT can still add the assets as unjustified wealth income.
Last updated: April 2026. Any figure marked <<CLIENT-CONFIRM>> is pending BOE / AEAT verification before publication.
Side-by-side comparison
| Criterion | Option 1 | Option 2 |
|---|---|---|
| Who must file | Spanish tax residents with qualifying foreign assets | Non-residents do NOT file |
| Asset categories | Accounts, securities, real estate | 3 categories, separate thresholds |
| Threshold per category | <<CLIENT-CONFIRM: 2026 EUR threshold per category>> | Typically €50,000 per category |
| Filing deadline | 31 March each year | For prior-year assets |
| Post-ECJ penalty regime | Standard tax-procedure penalties | No more disproportionate fines |
| Unjustified wealth risk | Still applies — late disclosure can trigger income imputation | <<CLIENT-CONFIRM: 2026 statute of limitations rules>> |
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The obligation runs in both directions, and buyers usually only hear about the Spanish half. A Belgian resident who acquires property abroad has a declaration to make at home, on a much shorter clock than most people expect — and it is their responsibility to start it, not their notary’s. the four-month declaration a Belgian buyer owes at home
Frequently asked questions
Do I need to file Modelo 720 every year?
Only in the first year above threshold per category; thereafter only if values grow by more than €20k in that category, or on exit (asset disposed).
Are UK accounts reportable?
Yes — UK is a foreign jurisdiction for Modelo 720 purposes. Spanish residents with UK banking/investment positions above threshold must declare.
Are US 401(k) / IRA accounts reportable?
Generally yes — they qualify as foreign securities/accounts. <
What if I missed a Modelo 720 in a prior year?
Voluntary late filing is usually better than audit detection. Post-ECJ, penalties are proportionate, but AEAT can still re-characterise the foreign asset as unjustified income if the filing is much too late.
What does Costaluz charge for Modelo 720 filing?
Flat fee per filing year (discount for multi-year catch-up). Email marialuisa@costaluzlawyers.es.
This article provides general guidance only and does not constitute legal advice. For personalised advice tailored to your specific situation, please book a consultation with our team.
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This content has been prepared with the assistance of artificial intelligence and reviewed by María Luisa de Castro, a lawyer specialising in Real Estate Law and founder of CostaLuz Lawyers.
The information provided is general and indicative in nature. It should not be used as the sole basis for making professional, legal or investment decisions, and CostaLuz Lawyers assumes no responsibility for decisions taken solely on the basis of this content.
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