Modelo 720 in Spain: Foreign Assets Reporting Guide

If you are tax resident in Spain and keep bank accounts, investments or property in another country, you may have to report them to the Spanish tax authority using Modelo 720.

Modelo 720 is one of the most misunderstood Spanish tax forms for foreign residents.

The first thing to understand is that it is an information return. Filing Modelo 720 does not itself create a tax charge.

Before dealing with Modelo 720, make sure you understand whether you are actually Spanish tax resident. See our Spanish Tax Residence Guide.

What Is Modelo 720?

Modelo 720 is the Spanish information return for certain assets and rights located outside Spain.

Its official name is:

Declaración informativa sobre bienes y derechos situados en el extranjero

Although it is one form, it contains three separate information obligations.

The Three Modelo 720 Reporting Blocks

Who Has to File Modelo 720?

The obligation can apply to:

• individuals resident in Spain;
• legal entities resident in Spain;
• permanent establishments in Spain of non-resident persons or entities; and
• certain other entities covered by Spanish tax law.

For most readers of this guide, the important group is individual Spanish tax residents who own assets outside Spain.

Do Non-Residents Have to File Modelo 720?

Ordinary individuals who are genuinely non-resident for Spanish tax purposes generally do not file Modelo 720 merely because they own property or other assets in Spain or abroad.

The reporting obligation is fundamentally linked to Spanish tax residence or one of the other specifically covered categories.

Does Having a CUE or TIE Mean You Must File Modelo 720?

No.

A CUE or TIE does not itself determine Spanish tax residence.

You first need to establish whether you are resident in Spain for tax purposes for the relevant calendar year.

See our NIE vs TIE vs CUE guide.

What Is the €50,000 Rule?

For the initial reporting obligation, each of the three main blocks is considered separately.

Broadly, no reporting is required for a block where the relevant aggregate value does not exceed €50,000, assuming no other rule creates an obligation.

That means you might have:

• €45,000 in foreign bank accounts;
• €45,000 in foreign investments; and
• €45,000 of reportable foreign property value

and the mere fact that the combined total is €135,000 does not automatically mean that all three blocks cross the Modelo 720 threshold.

Each block is tested under its own rules.

Is the Threshold €50,000 or More Than €50,000?

The statutory exemption generally applies where the relevant aggregate amount does not exceed €50,000.

In practical terms, the reporting threshold is triggered when the relevant amount is above €50,000.

Foreign Bank Accounts

The first block covers accounts with financial institutions situated outside Spain.

This can include accounts where you are:

• owner;
• co-owner;
• beneficiary;
• authorised person;
• person with power of disposal; or
• beneficial owner in circumstances covered by the rules.

Which Bank Balances Matter?

For foreign accounts, two figures are particularly important:

• the balance at 31 December; and
• the average balance during the final quarter of the year.

The threshold test for foreign accounts therefore does not depend simply on the highest balance reached at some point during the year.

Example: Foreign Bank Account

Suppose your only foreign account had:

• €65,000 in June;
• €46,000 at 31 December; and
• an average final-quarter balance of €47,000.

The fact that the account temporarily reached €65,000 earlier in the year does not by itself make the account reportable under the ordinary €50,000 account threshold.

What if You Have Several Foreign Accounts?

The relevant balances are considered together for the account block.

For example:

• Account A: €30,000;
• Account B: €15,000;
• Account C: €10,000.

The fact that no individual account exceeds €50,000 does not automatically remove the reporting obligation.

The aggregate value of the relevant foreign accounts must be considered.

What if You Are Only an Authorised Signatory?

Being authorised on a foreign account can itself fall within the reporting rules.

This is particularly important for people who:

• help manage a parent’s account;
• have authority over a family account;
• have signing authority for a company account; or
• retain powers over an account they do not personally own.

Specific exemptions can apply, particularly in properly recorded business situations, so the precise circumstances matter.

Joint Bank Accounts

Joint ownership does not necessarily mean that you apply the €50,000 test only to your personal percentage of the account.

AEAT’s guidance confirms that a jointly held account can be reportable when the account itself crosses the relevant threshold, even where each co-owner economically owns less than €50,000.

The declaration identifies the participation percentage.

Foreign Shares and Securities

The second reporting block includes certain securities and rights situated abroad.

This can include:

• shares in foreign companies;
• bonds and other securities;
• interests representing participation in entities;
• certain rights representing loans or capital provided to third parties; and
• certain assets held or managed through foreign legal arrangements.

Foreign Investment Funds

Shares or units in collective investment institutions situated abroad can also fall within Modelo 720.

The relevant valuation generally uses the liquidation value at 31 December.

What About Foreign Brokerage Accounts?

A foreign brokerage relationship can contain several different types of asset.

The fact that everything appears under one broker login does not necessarily mean it is treated as one bank account.

You may need to identify:

• cash balances;
• shares;
• funds;
• bonds;
• other securities; and
• the legal location and custodian arrangements.

Complex brokerage arrangements should be analysed according to the actual legal assets held rather than the appearance of the online platform.

Foreign Life Insurance

Certain life or disability insurance policies with insurers situated outside Spain fall within the securities, insurance and income-rights reporting block.

The relevant figure can include the surrender value at 31 December.

Not every insurance product is identical, so check the legal nature of the policy.

Foreign Annuities

Certain temporary or lifetime income rights obtained from transferring capital, assets or economic rights to an institution abroad can also be reportable.

These are valued using the applicable capitalisation rules.

Are Foreign Pension Plans Always Reportable?

Do not assume so.

Foreign pension products vary substantially.

Whether a pension arrangement falls within Modelo 720 can depend on its legal structure, whether the holder has a current economic or redemption right, and whether the arrangement constitutes a reportable security, insurance product or other right.

A normal foreign occupational pension cannot safely be classified simply from the word “pension.”

Foreign Property

The third Modelo 720 block covers:

• real estate situated abroad; and
• certain rights over foreign real estate.

This can include houses, apartments, land and other qualifying property interests outside Spain.

Which Value Is Used for Foreign Property?

For ordinary ownership, the acquisition value is central to the Modelo 720 reporting rules.

This is different from simply looking at today’s market price.

Special valuation rules apply to certain rights over property.

What if the Property Was Bought in Another Currency?

Modelo 720 values must be expressed in euros.

Foreign-currency amounts therefore need to be converted according to the applicable valuation rules.

Jointly Owned Foreign Property

Joint ownership requires care.

The existence of several owners does not automatically prevent the property from crossing the reporting threshold.

The declaration includes information about your participation in the asset.

Do not assume that a property worth €80,000 is irrelevant simply because you own only half of it.

What if You Inherit Property Abroad?

An inheritance can create a new foreign asset that needs to be considered for Modelo 720.

The relevant reporting analysis depends on:

• when you acquired the ownership or right;
• the nature of the inherited asset;
• its relevant Modelo 720 value;
• your percentage ownership; and
• whether the applicable reporting block crosses its threshold.

Inheritance tax and Modelo 720 are separate obligations.

Does Modelo 720 Tax the Foreign Asset?

No.

Modelo 720 is an information return.

It does not itself calculate:

• income tax;
• capital gains tax;
• wealth tax;
• inheritance tax; or
• another tax merely because the asset is declared.

However, the same asset or income generated by it may have consequences under other Spanish taxes.

Example: Foreign Bank Interest

Suppose you are Spanish tax resident and have €30,000 in a foreign savings account.

The balance may be below the Modelo 720 reporting threshold.

But interest earned on that account can still be taxable in Spain as part of your worldwide income.

Modelo 720 and Worldwide Income

A Spanish tax resident is generally subject to Spanish IRPF on worldwide income, subject to applicable double-tax treaties and relief for international double taxation.

Modelo 720 is separate from that income-tax obligation.

For example:

• foreign bank interest can be taxable even if no Modelo 720 is required;
• foreign dividends can be taxable even if the investment block is below €50,000;
• foreign rental income can be taxable even if the property is below the Modelo 720 threshold; and
• a foreign capital gain can be taxable even though the asset was never reportable on Modelo 720.

Do You File Modelo 720 Every Year?

Not necessarily.

Once you have filed a particular reporting block, you do not automatically repeat the entire declaration every year simply because you continue owning the same assets.

A later declaration for that block is generally required where the relevant aggregate value has increased by more than:

Example of the €20,000 Subsequent-Filing Rule

Suppose you reported foreign accounts because the relevant aggregate balance was €60,000.

The following year, the relevant aggregate amount is €72,000.

The increase is €12,000.

Assuming no other event independently requires reporting, the mere increase would not normally trigger a new Modelo 720 declaration.

If the relevant aggregate later rises above €80,000 by more than €20,000 compared with the amount that determined the previous filing, a new reporting obligation can arise.

Does Selling or Closing an Asset Matter?

Yes.

The €20,000 rule is not the only reason for a later filing.

If an asset or right was previously reportable and you:

• close a foreign bank account;
• sell a previously reported asset;
• cease to be an authorised person on an account;
• dispose of foreign property; or
• otherwise lose a previously reported ownership or right,

that change can itself have to be reported.

What if an Account Falls Below €50,000 and You Close It?

If the account was previously included in Modelo 720 because the relevant reporting obligation existed, its later closure can still need to be reported even if its value has subsequently fallen below €50,000.

The historical reporting status matters.

What if You Never Had to Report the Asset?

If you never had an obligation to report a particular block because the relevant threshold was never crossed, later disposal of an asset does not automatically create the same reporting requirement merely because it was sold.

The precise rules depend on the asset and reporting block.

When Is Modelo 720 Filed?

The ordinary filing period is:

For example, assets reportable for the year ending 31 December are normally declared between 1 January and 31 March of the following year.

How Is Modelo 720 Filed?

Modelo 720 is filed electronically through the Agencia Tributaria.

The official system provides an online form and related filing tools.

Depending on who submits the declaration, electronic identification can involve:

• Certificado Digital;
• DNIe;
• other permitted electronic identification; or
• an authorised tax representative.

See our Digital Administration in Spain guide.

Can a Gestor or Tax Adviser File It?

Yes.

An authorised adviser can prepare and submit Modelo 720 on your behalf.

This can be useful where you have:

• many foreign accounts;
• brokerage accounts containing different asset types;
• trusts or unusual legal structures;
• foreign pension arrangements;
• jointly owned assets;
• assets in several currencies; or
• changes to assets previously reported.

What Information Do You Need?

The information depends on the asset class.

It can include:

• name and address of the foreign bank or institution;
• account number or identifier;
• country;
• date you acquired the asset or became authorised;
• 31 December balance;
• average final-quarter account balance;
• value of securities or funds;
• insurance surrender value;
• property address;
• property acquisition date;
• property acquisition value;
• ownership percentage; and
• date and value when ownership or another reportable relationship ends.

Should You Keep Supporting Documents?

Yes.

Keep documents supporting the values and information reported.

Examples include:

• bank statements;
• broker statements;
• fund valuations;
• insurance statements;
• property purchase documents;
• inheritance documents;
• sale documents;
• currency-conversion calculations; and
• copies of earlier Modelo 720 filings.

What About Cryptocurrency?

Foreign virtual currencies are not simply added to Modelo 720.

Spain has a separate information return:

Modelo 721 has its own definitions, thresholds and rules.

Do not report foreign cryptocurrency under Modelo 720 merely because you know foreign assets have to be declared somewhere.

What About Cash Held at a Crypto Exchange?

This can be different from the cryptocurrency itself.

AEAT explains that fiat money such as euros, dollars or pounds held through a foreign exchange platform is not virtual currency for Modelo 721.

Depending on the legal structure of the account, the fiat balance can potentially fall within the foreign-account reporting rules of Modelo 720.

This is a good example of why the legal nature of the asset matters more than the name of the app or platform.

Modelo 720 vs Modelo 721

Does CRS Mean Modelo 720 Is Unnecessary?

No.

Many countries exchange financial-account information automatically under systems such as the Common Reporting Standard, or CRS.

That does not remove your personal Spanish reporting obligation where Modelo 720 applies.

The fact that AEAT may receive information about an account from another country is not a substitute for filing a required Modelo 720.

Will Spain Know About Foreign Bank Accounts?

Potentially, yes.

International tax-information exchange means Spanish tax authorities can receive information concerning foreign financial accounts through automatic exchange mechanisms and other cooperation arrangements.

Foreign assets should therefore not be treated as invisible merely because they are held outside Spain.

Does Modelo 720 Apply to Property in Your Home Country?

Yes, potentially.

The rules do not exempt an asset simply because:

• you owned it before moving to Spain;
• it is in your country of citizenship;
• you inherited it years ago;
• you never transferred money from Spain to buy it; or
• it has never generated income.

If you become subject to the Modelo 720 reporting obligation, pre-existing foreign assets can be relevant.

What if You Owned the Asset Before Becoming Spanish Tax Resident?

The fact that you acquired an asset before moving to Spain does not by itself exclude it from Modelo 720.

The reporting question is whether you are within the reporting regime for the relevant year and whether the asset meets the applicable conditions.

What if You Become Spanish Tax Resident Halfway Through a Year?

Spanish tax residence for individuals generally operates by calendar year rather than through an ordinary split-year system.

If you are Spanish tax resident for the relevant year, your foreign assets must be tested against the Modelo 720 rules for that reporting period.

This is one reason why determining tax residence correctly should come before deciding whether Modelo 720 applies.

Is Modelo 720 the Same as Wealth Tax?

No.

Modelo 720 is an information return.

Spanish Wealth Tax — Impuesto sobre el Patrimonio — is a separate tax with different:

• taxable persons;
• valuation rules;
• exemptions;
• thresholds;
• regional rules; and
• filing requirements.

You may need one, both or neither depending on your circumstances.

Is Modelo 720 the Same as Your Income-Tax Return?

No.

Your IRPF return reports taxable income and gains.

Modelo 720 reports specified foreign assets and rights.

An asset can therefore be relevant to both systems in different ways.

Example: Foreign Rental Property

Suppose you are Spanish tax resident and own an apartment abroad.

You may need to consider:

• Modelo 720 because you own foreign real estate;
• IRPF because the property produces rental income;
• IRPF rules for periods when the property is not rented, where applicable;
• foreign tax paid on the property;
• double-taxation relief; and
• potential wealth-tax consequences.

These are separate compliance questions.

What Are the Penalties for Not Filing Modelo 720?

Modelo 720 became notorious because the original Spanish penalty regime was exceptionally severe.

That regime was challenged by the European Commission, and the Court of Justice of the European Union ruled against important aspects of Spain’s system in January 2022.

Spanish law was subsequently amended.

AEAT now states that Modelo 720 failures are subject to the general penalty regime under the Spanish General Tax Law for information returns.

Does That Mean Late Filing Is Harmless?

No.

The elimination of the former extraordinary regime does not eliminate the filing obligation.

Late, missing, incomplete or inaccurate information can still fall under the ordinary Spanish tax penalty rules.

What if You Discover an Old Modelo 720 Was Wrong?

Do not ignore the error simply because the original filing period has passed.

AEAT provides mechanisms for:

• supplementary declarations;
• replacement declarations; and
• consulting and modifying previously filed information returns.

The correct method depends on what needs to be changed.

What if You Should Have Filed but Never Did?

The safest course is to reconstruct the relevant years and assets before filing anything blindly.

Determine:

1. when you first became Spanish tax resident;
2. which foreign assets you held;
3. which reporting block each asset belongs to;
4. whether each block crossed its threshold;
5. whether later €20,000 increases occurred;
6. whether previously reportable assets were sold or closed; and
7. which declarations are actually missing.

For substantial historic omissions, professional tax advice is sensible before correcting the position.

Common Modelo 720 Mistakes

“I have more than €50,000 abroad in total, so I automatically file.”

Not necessarily. The three information blocks have separate threshold tests.

“Every individual asset must exceed €50,000.”

No. Assets within a reporting block are generally considered together for threshold purposes.

“If I own only 50% of a €90,000 foreign account, I am below the limit.”

Do not assume so. Joint ownership has specific reporting rules and AEAT looks at the account’s relevant total value when testing the threshold.

“I file Modelo 720 every year once I have filed once.”

Not automatically. Subsequent-filing rules depend on increases and other reportable changes.

“If the value falls below €50,000, I never have to report it again.”

Incorrect. Closure, sale or loss of a previously reported relationship can itself be reportable.

“Modelo 720 is a tax.”

No. It is an information return.

“If no Modelo 720 is required, foreign income is tax-free.”

No. Income-tax rules operate separately.

“My foreign property was bought before I moved to Spain, so it does not count.”

That fact alone does not exclude it.

“Cryptocurrency goes on Modelo 720.”

Foreign virtual currency has its own Modelo 721 reporting regime.

“CRS reports my accounts automatically, so I do not need Modelo 720.”

No. Automatic information exchange does not replace your own filing obligation.

“The old enormous Modelo 720 penalties still apply unchanged.”

No. The penalty regime was changed following the 2022 EU Court judgment.

Modelo 720 Checklist

Modelo 720: The Short Version

Modelo 720 is Spain’s information return for certain assets and rights held abroad.

It contains three separate reporting blocks:

• foreign financial accounts;
• foreign securities, investments, certain insurance and income rights; and
• foreign real estate.

The initial reporting threshold is generally more than €50,000 for each block separately.

After a block has been reported, a new declaration is not automatically required every year. A later filing is generally triggered by an increase of more than €20,000 compared with the value that determined the previous declaration, or by certain events such as disposing of or closing a previously reported asset.

The filing period is normally 1 January to 31 March of the following year.

Modelo 720 does not itself impose tax, but the foreign income and assets can separately affect IRPF, Wealth Tax and other Spanish taxes.

Foreign cryptocurrency is dealt with separately under Modelo 721.

Where to Go Next

• Spanish Tax Residence Guide
• How to Update Your Tax Address With Modelo 030
• Digital Administration in Spain