Modelo 720

Last updated: 2026-05-16

Modelo 720 is the annual informational return on foreign-situated assets and rights that Spanish tax residents must file. It was introduced by Law 7/2012 of October 29 on prevention and fight against tax fraud, and developed by Royal Decree 1558/2012 and Order HAP/72/2013. It is not a tax — nothing is paid for filing it. It is information used by the Spanish Tax Agency (AEAT) to cross-reference with foreign authorities via CRS, FATCA and OECD automatic exchanges.

Who must file

Any individual or legal entity with tax residency in Spain (Art. 9 LIRPF) who is owner, representative, authorized signatory, beneficiary or holds power of disposition over foreign assets, when the aggregate value of at least one of the three categories at December 31 exceeds €50,000. Beneficial owners under Law 10/2010 (anti–money laundering) are also obliged (typically >25% interest in opaque structures).

Once filed, you only file again in subsequent years if any category increases by more than €20,000 versus the last filed 720, or if you cease to be owner of any previously declared asset.

The three asset categories

1. Accounts at foreign financial institutions

Includes current accounts, savings, term deposits, credit accounts and equivalent products at banks outside Spain. Typical for digital nomads: Wise, Revolut Lithuania, German N26, Portuguese/Georgian/Thai bank accounts, US neobanks (Mercury, Wise USD).

Both year-end balance (December 31) and average balance of the last quarter must be declared. The obligation arises if the sum of all foreign accounts exceeds €50,000 under either metric.

2. Securities, rights, insurance and income deposited or managed abroad

Covers shares, fund holdings, ETFs, bonds, life insurance with surrender value, foreign pension plans, holdings in non-resident companies and annuities managed by foreign entities. This is where an Interactive Brokers Ireland portfolio, Trade Republic shares, Degiro ETFs, equity in a UK LTD, an Estonian OÜ or a Wyoming LLC belong.

Important: crypto-assets custodied by foreign exchanges are no longer declared here since 2024 — they have their own form, the Modelo 721.

3. Real estate and rights over real estate situated abroad

Flats, houses, commercial premises, rural land, parking spaces, timeshare and real rights (usufruct, bare ownership, time-sharing rights) over real estate outside Spain. Declared at acquisition value, not current market value.

Deadlines and filing

• Deadline: January 1 to March 31 of the year following the reporting year. The 720 for fiscal year 2025 is filed between January 1 and March 31, 2026.
• Form: electronic only via the AEAT electronic office, using digital certificate, Cl@ve PIN or electronic ID.
• No paper filing. No filing through an unauthorized agent.

The CJEU ruling C-788/19 (January 27, 2022)

"The Kingdom of Spain has failed to fulfil its obligations under the free movement of capital (Art. 63 TFEU) by establishing consequences for non-compliance or late compliance with the reporting obligation on foreign-situated assets that are disproportionate." — CJEU, Case C-788/19

The European Commission brought Spain before the Court of Justice of the EU, which declared inapplicable three key elements of the 720 sanction regime:

1. The classification as unjustified capital gain without statute of limitations of undeclared or late-declared assets (Art. 39.2 LIRPF and Art. 121.6 LIS), which let Hacienda tax assets acquired decades earlier at the top marginal rate with no way to prove the period was statute-barred.
2. The proportional fine of 150% of the value of undeclared assets.
3. The fixed formal fines of €5,000 per omitted data point, with a minimum of €10,000.

Spain adapted the rules via Law 5/2022 of March 9, eliminating those three points. What remains fully in force:

• The obligation to file Modelo 720.
• The general sanction regime of the General Tax Law (LGT, Law 58/2003): €150 for late filing without prior request, fines of €150 to €1,500 for filing with incorrect data, and up to €10,000 in serious cases of resistance.
• Hacienda's ability to cross-check information with foreign banks via CRS and open a review if it detects undeclared foreign balances in income tax (IRPF) filings.

Difference with Modelo 721

	Modelo 720	Modelo 721
Year introduced	2012	2024
What it declares	Accounts, securities, real estate	Foreign-custodied crypto
Threshold	€50,000 per category	€50,000 aggregate
Self-custody (hardware wallet)	Not applicable	Excluded
Deadline	Jan 1 – Mar 31	Jan 1 – Mar 31

They coexist: if you hold €60,000 in Interactive Brokers Ireland and €70,000 on Coinbase, you file both.

Three practical cases

Case 1 — Nomad in Portugal with a Wise UK account. Marta moved to Lisbon in March 2025 and holds €35,000 in her Wise GBP (UK) and €20,000 in Wise EUR (Belgium). Does she file 720 for fiscal year 2025? It depends on whether she was a Spanish tax resident during 2025. If she spent >183 days in Spain during 2025 before moving, or kept her center of economic interests there (main client billed from Madrid, habitual residence, family), yes: aggregating both accounts exceeds €50,000 and she must declare. If she correctly broke residency with Modelo 030 and obtained a Portuguese certificate before July 2, 2025, no.

Case 2 — Crypto trader with USDT on Coinbase + MetaMask. Pablo, a Spanish tax resident, holds $80,000 in USDT and BTC on Coinbase and another $30,000 in a MetaMask wallet he custodies himself with his seed phrase. What does he declare? The $80,000 on Coinbase go on Modelo 721 (foreign third-party custody, exceeds €50,000). The $30,000 on MetaMask self-custody are not declared in either 720 or 721 because the AEAT considers that in self-custody there is no foreign third-party custodian against whom to apply the reporting duty. Of course: any capital gains on sale still tax in IRPF at 19–28%, regardless of custody.

Case 3 — Entrepreneur with an Estonian company. Lucía is a Spanish tax resident and sole shareholder of an Estonian OÜ. The company holds €40,000 in its corporate account at LHV Bank (Estonia) and Lucía holds shares valued at €30,000 in her own OÜ. Does she cross the threshold?

• The OÜ's corporate account is not hers personally: it does not enter her personal Modelo 720 (the OÜ is a separate legal entity). It would only enter if Lucía is a beneficial owner or authorized signatory with personal power of disposition.
• The OÜ shares (€30,000) enter category 2 (foreign-deposited securities) and add to any other foreign-deposited security. €30,000 alone do not exceed €50,000, so no obligation. If she also held €25,000 at Interactive Brokers Ireland, the category 2 total would be €55,000 and filing would be required.

What happens if you don't file and you're a Spanish tax resident (post-CJEU)

After the CJEU ruling and Law 5/2022, the scenario is very different from 2012–2022:

• The 150% fine and the no-statute-of-limitations classification of unjustified capital gains no longer apply.
• The general LGT sanction regime does apply: €150 for late filing without prior request (Art. 198 LGT), €150 to €1,500 for filing with incorrect data, and €200 penalties per false or incomplete data point.
• Hacienda can open a limited review or full inspection if it detects undeclared foreign balances via CRS, and force you to regularize IRPF for the non–statute-barred years (4 years) if the funds were not declared as income at source.
• The exit tax operates independently of 720 if you lose tax residency with >€4M in equity holdings.

In other words: the main risk today is not the 720 fine itself — it's that the CRS cross-check triggers an IRPF inspection that uncovers undeclared income. The 720 is the trap, not the stick.

Official sources

• Law 7/2012 of October 29, modifying tax and budgetary rules — BOE-A-2012-13416.
• CJEU Judgment Case C-788/19 of January 27, 2022 — European Commission v. Kingdom of Spain.
• Law 5/2022 of March 9, adapting the 720 sanction regime to the CJEU doctrine — BOE-A-2022-3702.
• AEAT — Modelo 720: information, instructions and electronic filing on the Spanish Tax Agency's electronic office.
• Order HAP/72/2013, approving Modelo 720, the informational return on foreign-situated assets and rights — BOE-A-2013-954.