Spanish tax residents holding foreign assets exceeding €50,000 must file Form 720 annually between January 1 and March 31. For fiscal year 2025 (assets held as of December 31, 2025), the deadline is March 31, 2026. Following the 2022 CJEU ruling, penalties have been significantly reduced to align with general Spanish tax law, but the declaration obligation remains mandatory.
Understanding Form 720: Spain’s Foreign Asset Declaration
Form 720 (Modelo 720 in Spanish) represents one of Spain’s most rigorous tax transparency mechanisms, requiring Spanish tax residents to disclose foreign assets and rights exceeding specific thresholds. Introduced in 2013 as part of Spain’s commitment to combating tax evasion and promoting financial transparency, this informative declaration serves as a cornerstone of Spain’s international tax compliance framework.
For international clients navigating Spain’s tax system, Form 720 often generates significant anxiety—and for good reason. The form’s technical complexity, combined with historically severe penalties, has made it one of the most feared tax obligations among expatriates, investors, and foreign residents in Spain.
Who Must File Form 720 in 2026?
Tax Residency: The Fundamental Criterion
The obligation to file Form 720 applies exclusively to Spanish tax residents. You are considered a Spanish tax resident if you meet any of these conditions:
- You spend more than 183 days in Spain during the calendar year (including sporadic absences unless you prove tax residency elsewhere).
- Your center of economic interests is located in Spain (where you derive the majority of your income).
- Your spouse and dependent children habitually reside in Spain (unless legally separated).
Key consideration for visa holders: If you moved to Spain in 2025 on a Non-Lucrative Visa or Digital Nomad Visa, you likely became a Spanish tax resident and must file Form 720 if your foreign assets exceed the thresholds.
Obligated Parties Beyond Individuals
Form 720 extends beyond natural persons to include:
- Legal entities resident in Spanish territory.
- Permanent establishments in Spain of non-resident entities.
- Entities without legal personality (undivided estates, property communities, civil partnerships).
- Beneficial owners of assets held through trusts, foundations, or corporate structures who exercise more than 25% control or have disposal rights.
The Three Asset Categories: What Must Be Declared?
Form 720 organizes foreign assets into three distinct reporting blocks, each with an independent €50,000 threshold:
Category 1: Bank Accounts and Financial Deposits
You must declare foreign accounts where you are: Holder, Authorized signatory, Beneficiary, or Representative.
Required information includes:
- Complete bank name and address.
- Account identification numbers (IBAN or equivalent).
- Account type (current, savings, deposit, custody).
- Balance as of December 31st.
- Average balance for the fourth quarter (October-December).
- Percentage of ownership.
Critical note: For bank accounts, you must declare if either the December 31st balance or the Q4 average balance exceeds €50,000 cumulatively across all your foreign accounts.
Category 2: Securities, Investments, and Financial Rights
This category encompasses shares, investment funds, life insurance policies, bonds, and pension plans.
Valuation: Securities must be reported at their market value as of December 31st, converted to euros using the official Bank of Spain exchange rate for that date.
Category 3: Real Estate and Property Rights
All foreign real estate must be declared (residential, commercial, land, or rights like usufruct).
Valuation: Properties are declared at acquisition value (purchase price), not current market value.
The €50,000 Threshold: A Critical Distinction
Independent Category Thresholds
The €50,000 limit applies separately to each of the three categories:
- Bank accounts > €50,000: Declare ALL accounts.
- Securities < €50,000: No declaration needed for this block.
- Real Estate > €50,000: Declare ALL real estate.
Joint Ownership Complexity
For jointly owned assets, each owner must declare the full value of the asset and specify their ownership percentage.
Example: A married couple jointly owns a French property worth €80,000. Both spouses must each declare an asset valued at €80,000 with 50% ownership.
When Must You File Form 720?
Annual Filing Window: January 1 to March 31, 2026
Form 720 must be filed electronically between January 1 and March 31 of the year following the reference year. Deadline: March 31, 2026, 23:59 CET. There are no extensions.
Subsequent Year Filing Requirements
After your initial filing, you are not required to file every year unless:
- Any previously declared category has increased in value by more than €20,000.
- You have sold, transferred, or closed any previously declared asset.
- A new category has exceeded €50,000.
How to File Form 720: The Electronic Submission Process
Form 720 submission is exclusively electronic. You must have a Digital certificate, electronic DNI (DNIe), or Cl@ve system credentials.
Common Filing Errors to Avoid:
- Incorrect valuation: Using market value for real estate instead of purchase cost.
- Missing signatories: Forgetting accounts where you only have signing authority.
- Wrong currency conversion: Not using the official Bank of Spain rate for Dec 31st.
The Post-CJEU Sanction Regime: Understanding Your Risks
On January 27, 2022, the Court of Justice of the European Union (CJEU) declared Spain’s original penalty regime contrary to EU law. Spain amended its legislation through Law 5/2022.
Current Penalty Framework (2026)
Violations now fall under the general sanctioning regime:
- Failure to file: €200 per asset category (maximum €600).
- Late filing (voluntary): €100 per asset category.
- Inaccurate information: €150 fixed fine per data item.
Statute of limitations: A standard 4-year prescription period now applies.
Special Situations Requiring Expert Guidance
Cryptocurrency and Digital Assets
As of 2025, cryptocurrencies are NOT reported on Form 720. Instead, they require Form 721 with the same thresholds and deadlines.
Pension Schemes and Retirement Accounts
Whether foreign pension plans must be declared depends on their legal structure and your degree of control. Self-invested pensions (SIPPs) are generally declarable.
New Residents and the First-Year Obligation
If you became a resident in 2025, your first Form 720 is due by March 31, 2026. Form 720 is based on your current tax residency status, not when you acquired the assets.
2026 Spanish Tax Calendar: Key Dates for Foreign Residents
| Date | Obligation | Who |
|---|---|---|
| March 31 | Form 720 & 721 | Residents with foreign assets/crypto >€50k |
| April 2 – June 30 | Annual Income Tax (Modelo 100) | Tax residents |
| June 30 | Wealth Tax (Modelo 714) | High net worth residents |
| December 31 | Non-resident tax (Modelo 210) | Non-resident property owners |
Practical Examples: Form 720 in Action
Example 1: The UK Retiree
Margaret (Valencia resident) has a UK bank account (€41,650) and a UK rental property purchased for £180,000. She must file Form 720 only for the property (Category 3) because the bank account is below the €50k threshold.
Example 2: The Digital Nomad
James (US remote worker) has $45k in bank accounts and $72k in a Vanguard brokerage. He must file only for the securities (Category 2) as the bank balance is below the threshold.
Why Professional Assistance Makes the Difference
Mistakes remain costly due to technical penalties and potential audits. At Lextax, our cross-border tax team has guided hundreds of international clients through Form 720 compliance, ensuring your global holdings are correctly valued and filed.
Ready to Ensure Flawless Form 720 Compliance? Don’t leave your declaration to chance. Contact Lextax today for a comprehensive review before the March 31, 2026 deadline.
Visit us at www.lextax.es to schedule your personalized consultation.
Frequently Asked Questions (FAQs)
Do I need to file Form 720 every year?
No. Only if you have an increase of >€20,000 in a category, a new category exceeds €50,000, or you dispose of an asset.
I have the Beckham Law—do I still need to file Form 720?
Absolutely. The Beckham Law affects income tax but does not exempt you from Form 720 reporting requirements.
Are joint accounts reported at 50% or 100% of their value?
Each holder must declare the full account value and specify their ownership percentage.
