Modelo 720 and 721: Reporting Foreign Assets from Spain

If you live on Mallorca as a tax resident and hold accounts, investments or property abroad, there is no way around the Modelo 720. The filing costs you nothing in tax; it is purely an information return for the Agencia Tributaria. Since tax year 2023, cryptocurrency is reported on a separate form, the Modelo 721. This post explains the thresholds that trigger the obligation, when a follow-up filing is due and why the once-feared penalties no longer exist in that form. Whether you count as a resident in the first place is covered in our guide to tax residency on Mallorca.

What is the Modelo 720?

The Modelo 720 is an annual information return through which taxpayers resident in Spain report their assets abroad to the Agencia Tributaria. No tax is due on the filing itself. You become obliged to report when accounts, securities or real estate abroad are worth more than 50,000 euros combined in any of the three categories as of December 31.

The distinction matters: the Modelo 720 is a report, not a levy. Tax on your assets runs separately through the wealth tax in the Balearics, and the income from those assets through income tax. All forms, deadlines and the technical filing process are on the official page of the Agencia Tributaria for the Modelo 720.

The three categories and the 50,000 euro threshold

Behind the single form sit three legally separate reporting obligations. Each is assessed on its own:

• Accounts at financial institutions abroad: current accounts, savings, fixed-term deposits. Besides the balance on December 31, the average balance of the last quarter also counts.
• Securities, rights, insurance and pensions abroad: brokerage accounts, funds, shares, life insurance with a surrender value, private pension products.
• Real estate and rights over real estate abroad: the house in your home country, but also usufruct or partial ownership.

The 50,000 euros apply per category, not in total. A brokerage account worth 60,000 euros in your home country triggers the reporting obligation even if you hold nothing else abroad. Conversely, you stay out of scope if each category individually sits below the threshold, even when the combined total exceeds it. How the income from such an account is then taxed in Spain is covered in our post on capital gains and investment accounts in Spain.

Modelo 721: crypto has its own form

Cryptocurrency does not belong in the Modelo 720. Since Orden HFP/886/2023, it is covered by the Modelo 721, first applied to tax year 2023. The threshold is also 50,000 euros, calculated on the combined value of all coins as of December 31.

What matters is who holds the private keys. Only balances that a service provider abroad holds for you are reportable, typically an exchange or custody provider outside Spain. Platforms based in Spain report to the tax administration themselves anyway.

Do I have to declare my hardware wallet in the Modelo 721?

No. If you keep the private keys yourself, no report is due. In its answers on the Modelo 721, the Agencia Tributaria makes clear that hot wallet versus cold wallet is not the point; what counts is custody by a third party.

Deadlines and when you must file again

Both filings share the same window: from January 1 to March 31 of the year following the reference date. For tax year 2026, the last filing day is therefore March 31, 2027. Filing is exclusively electronic via the Sede Electrónica, in practice with a digital certificate or Cl@ve.

After the first filing, things calm down. A new return is only required if one of these applies:

1. The value of a category has risen by more than 20,000 euros compared with the last filed return.
2. You gave up a reported position during the year, meaning you closed the account, sold the securities or transferred the property. In that case you report the values at the time of disposal.
3. A category exceeds 50,000 euros for the first time and was therefore not included before.

Do I have to file the Modelo 720 every year?

No. Without one of these three changes, there is nothing to submit. The benchmark, however, is the last return you actually filed, not the previous year. With fluctuating portfolio values, a short annual check is worth it.

What happens if you do not report

The Modelo 720 long had a bad reputation, and it was deserved: unreported foreign assets were treated as unjustified capital gains with no statute of limitations, on top of a 150 percent penalty and fixed fines of 5,000 euros per data item. The European Court of Justice struck down this regime on January 27, 2022 in case C-788/19 as disproportionate. Spain removed it with Ley 5/2022 of March 9, 2022.

Today the general penalty regime of articles 198 and 199 of the Ley General Tributaria applies, as the Agencia Tributaria describes in its answers on penalties:

Case	Fine
No filing, tax office demands it	EUR 20 per data item, minimum 300, maximum 20,000
Voluntary late filing, without a demand	EUR 10 per data item, minimum 150, maximum 10,000
Filing incomplete or incorrect	EUR 20 per data item, minimum 300

Two points are often overlooked. First, the amounts apply per reporting obligation, so up to three times if you concealed accounts, securities and real estate at once. Second, voluntary late filing makes a real difference, because both the fine and the caps are halved. If you have missed several years, do not untangle that without a tax advisor, because alongside the report the income tax returns of the affected years usually need correcting too.

Conclusion

The Modelo 720 sounds more threatening than it is today. It costs no tax, only affects assets above 50,000 euros per category and after the first filing usually does not need repeating for years. Crypto on foreign platforms has run separately through the Modelo 721 since tax year 2023, while self-custodied coins stay out of scope. What to remember: the reference date is December 31, and the filing window closes on March 31 of the following year.

The effort lies less in the form than in clean documentation. Collect year-end statements, portfolio values and account balances for the turn of the year, and the filing becomes an hour's work. With several foreign accounts, an inherited property or missed years, a Spanish tax advisor is worth the money.