Foreign Assets & Rights
📊 Evaluation by Independent Asset Blocks
The informative declaration of assets and rights held abroad, filed through Form 720 (Modelo 720) for bank accounts, investments, and real estate, and Form 721 (Modelo 721) for foreign-custodied cryptocurrencies, is one of Spain’s most closely monitored tax compliance measures. Introduced by Law 7/2012, of October 29, it requires all tax residents in Spain (both individuals and corporations) to report detailed information to the State Tax Agency (AEAT) about assets held outside the country, provided the total value of any of the four independent asset blocks exceeds €50,000.
🔍 The 4 Independent Asset Blocks and Thresholds
The obligation to file Form 720 and 721 is evaluated separately for each of the following groups of assets. Exceeding the €50,000 limit in one group triggers the obligation for that specific block, even if the other groups remain below the limit:
- Bank Accounts Block: Bank accounts, savings accounts, or deposits held in foreign financial institutions (e.g., Revolut with Lithuanian IBAN, N26 German account, cash balances in foreign brokerage accounts).
- Stocks and Investments Block: Shares, bonds, holdings in mutual funds (e.g., inside foreign brokers like DeGiro or Interactive Brokers), foreign pension plans, or life insurance policies contracted abroad.
- Real Estate Block: Residential properties, commercial premises, land, or real property rights located outside of Spain.
- Cryptocurrencies Block (Form 721): Virtual currencies held on platforms or custody services abroad that safeguard private cryptographic keys on behalf of users (e.g., Binance or Coinbase).
📝 Worked examples
Example 1: Freelancer with a foreign bank account and national investments
Profile: A Spanish tax resident holds a savings account in a Swiss bank with a balance of €45,000.00. He also holds a stock portfolio worth €60,000.00 at a Spanish national bank.
- Foreign accounts block: €45,000.00 (Exempt, below the €50,000 threshold)
- National investments: Excluded from foreign assets reporting because the assets are held in Spain.
Example 2: Resident with foreign real estate and stocks in a foreign brokerage account
Profile: Owns a flat in France valued at €60,000.00 and a stock portfolio in a German brokerage account (Interactive Brokers) worth €15,000.00.
- Real estate block: €60,000.00 (Filing required, exceeds €50,000)
- Foreign investments block: €15,000.00 (Exempt, below €50,000)
Example 3: Crypto investor with assets in Binance and a hardware wallet
Profile: Spanish resident holding €60,000.00 in bitcoins on Binance (an exchange based outside Spain) and €80,000.00 in a private Ledger hardware wallet (held locally).
- Crypto on foreign exchanges (Binance): €60,000.00 (Filing required, exceeds €50,000, reported on Form 721)
- Crypto on hardware wallet (Ledger): Excluded from Form 721 because the private keys are held locally under the sole control of the owner and not custodied by a foreign third party.
⚠️ Common mistakes
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Confusing Form 720/721 with a tax payment: These are informative declarations only. Filing them does not result in paying any tax or fee. However, failing to file them or submitting incorrect data leads to severe penalties from the AEAT.
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Failing to file when assets have multiple co-owners: If a foreign property is worth €80,000.00 and is owned 50/50 by a married couple who are both tax residents in Spain, both spouses must file Form 720. The obligation is triggered because the total asset value exceeds €50,000.00, regardless of the individual ownership percentages. Each spouse must declare the property indicating their 50% share.
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Forgetting to declare accounts with changed IBANs: Some fintech accounts that previously carried foreign IBANs (e.g., Revolut before migrating to Spanish IBANs) required Form 720 if the balance exceeded €50,000. Now that they carry Spanish IBANs, they are excluded from Form 720.
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Filing every year without changes: If you filed Form 720 in a previous year, you do not need to file it again the following year unless:
- The total value of an asset block already declared increases by more than €20,000 compared to the last filed return.
- You close a previously declared bank account, sell a property, or sell foreign securities.
❓ Frequently Asked Questions (FAQ)
Both forms must be filed online between **January 1st and March 31st** each year, reporting the balances and asset values as of December 31st of the previous calendar year.
The Court of Justice of the European Union ruled that Spain's original penalty system was disproportionate and violated the free movement of capital. Spain removed the minimum €10,000 fines and the lack of a statute of limitations, aligning the penalties with general Spanish tax laws.
Yes. Foreign pension plans are included in the investments and insurance block. If the total accumulated rights in the plan exceed €50,000, they must be reported on Form 720.
For the bank accounts block, the obligation is triggered if your balance exceeds €50,000 on December 31st **OR** if your weighted average balance in the last quarter of the year (October to December) exceeds €50,000.
No. These reporting requirements apply exclusively to individuals and corporations who qualify as tax residents in Spain. Non-residents are completely exempt.
No. Form 721 is only required for crypto assets custodied by foreign third-party platforms. If your keys are held in self-custody software or hardware wallets, you do not need to report them on Form 721.
Dividends received are added to your brokerage cash balance (accounts block) or reinvested in stocks (investments block). They only affect your filing status if they increase the total value of the block beyond the €50,000 threshold.
Following the EU-mandated reforms, filing Form 720 late without prior tax office notice carries a flat fine of **€150** or general reduced penalties under standard Spanish tax administration rules.