Reporting Assets Outside of Spain: Modelo 720/721
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Modelo 720 and 721 of the Agencia Estatal de Administración Tributaria (AEAT) are required to report all assets abroad and must be filed by all Spanish residents owning assets abroad, only if they are over the limits described below.
What Are the Modelo 720 and 721?
Modelo 720 was approved on October 29, 2012, as part of the financial regulations to intensify actions in the prevention and fight against fraud.
Modelo 721 started was introduced in 2024 as the informative declaration on virtual currencies located abroad and it works as an independent fourth block of the 720.
- They are informative returns on assets and rights located abroad and have the following objectives:
- To report on accounts in financial institutions located abroad.
- To report on securities, rights, insurance policies and income deposited, managed or obtained abroad.
- To report on real estate and rights to real estate located abroad.
- To report cryptocurrencies located abroad (Modelo 721)
The Law divides the assets to be reported into three different blocks (Modelo 720):
1. Accounts in Financial Institutions Abroad
This includes current accounts, savings accounts, term deposits, credit accounts. Information on each account should include the balance of these accounts on December 31st, the average balance for the last quarter of the year and the date of opening. Also, if you are an account holder or authorized holder.
Holders and authorized holders, who have ceased to be during the year, must indicate only the balance of the day they ceased to be holders or authorized holders.
2. Stocks, Bonds, Values, Financial Rights and Savings in Insurance Companies, Deposited, Managed or Obtained Abroad
- a. Securities or rights located overseas, representative participation in any type of legal entity; values located overseas representative of the transfer of capital to third parties or provided for its management or administration to any legal instrument, including “trusts” though lacking legal personality, capable of acting in the course of trade.
- b. Shares and participation in share capital or equity funds of collective investment institutions located abroad.
- c. Life insurance (savings not risk) or pensions or annuities, whose insurance companies are located overseas.
3. Real Estate
All types of Real Estate and rights over Real Estate abroad, which include ownership of the property, actual use or enjoyment and bare ownership rights over real estate, timeshares, timeshares shifts, part-time property or similar formulas on real estate, other rights in rem over real estate.
Who Is Required to File Modelo 720/721?
All natural and legal persons resident in Spanish territory, permanent establishments in said territory of non-resident persons or entities, and the entities referred to in Article 35.4 of Law 58/2003 are required to file Modelo 720/721.
The holder, representative, authorized person, beneficiary, person or entity with powers of disposal, or beneficial owner, is required to report accounts in financial institutions located abroad, securities, rights, insurance policies and income deposited, managed, or obtained abroad, and real estate and rights over real estate located abroad.
There is no obligation to report any assets in the block where the sum of the assets does not exceed €50,000. In blocks where the sum exceeds this amount, there is an obligation to report all the assets included. With regard to the block of accounts in financial institutions, it is sufficient that the sum exceeds €50,000, or the sum of the balances as of December 31 of the corresponding year, or the sum of the average balances. In subsequent years, only blocks with an increase exceeding €20,000 compared to the last declaration filed will be reported.
How to Complete Modelo 720/721
Modelo 720 must be completed electronically via the internet and can be submitted either by the taxpayer or by a third party acting on their behalf.
When to File Modelo 720/721
The informative return on assets and rights located abroad must be filed between January 1st and March 31st of the year following the one to which the information in Modelo 720/721 refers.
Modelo 720/721 must be filed for the first time if any of these blocks exceeds the amount of €50,000 and only the block in which the amount is exceeded and the consecutive years if there is an increase of €20,000 on the different blocks.
Penalties
The penalty for filing the 720/721 after the deadline is €200. The penalty for not filing, filing an incomplete form, or filing with inaccurate data: €150 + €20 for each piece of data or set of data referred to the same entity, with a minimum of €300 and a maximum of €20,000. If there has been no prior request from the tax agency, these fines will be reduced by half.
Cooperation with Other States
A Royal Decree was approved to replace the European Community´s former guidelines that regulated the cooperation of the different government administrations in the field of taxation, thus, reinforcing cooperation in the exchange of information between countries for the liquidation of taxes.
Among other issues, this decree conferred legal capacity to the tax agency to formulate requests for mutual assistance to other states or international organizations. This provides legal security to achieve greater agility in the process of mutual assistance.
A few years ago the tax agency began to provide tax information for citizens of the EU to their respective countries. This is done via Form 299, which is filled by Spanish financial institutions and collected and processed by the tax authority.
A Practical Workflow: From December Data to March Filing
To avoid last-minute headaches, consider this timeline:
Early December
- Identify all foreign institutions: banks, brokers, insurers, crypto exchanges/custodians.
- Confirm account numbers, policy numbers, wallet/exchange IDs and contact details.
- Review last year’s submission to see which blocks you filed and where a €20,000 increase may occur.
Late December
- Capture December 31st balances for accounts (and remember to compute the Q4 average).
- For real estate, reconfirm the acquisition value and ownership percentages.
- For investments and insurance, download year-end statements.
- For crypto (721), export end-of-year holdings, valuation snapshots, and transaction summaries if needed.
Early January
- Apply the ECB exchange rate to convert values to euros.
- Test €50,000 thresholds per block; if filing again, test the €20,000 increase rule.
- Draft entries for each asset, including capacity (holder/authorized/beneficiary) and relevant dates.
January–February
- Enter data into the AEAT electronic forms (720 and/or 721).
- Cross-check for accuracy: names, ID numbers, addresses of institutions, balances, dates and roles.
- Create a supporting file (PDF binder or folder) with statements, ECB rate printouts and calculations.
March
- File electronically before March 31st.
- Save filing confirmations and keeping your working papers for your records.
Do You Need Help?
In an increasingly complex international tax landscape, having the right guidance makes all the difference. At US Tax Consultants, clients receive clear, reliable and personalized support tailored to their cross-border obligations. Whether you need help understanding your U.S. filing requirements, navigating estate and gift reporting, or planning ahead with confidence, their team is ready to assist. For more information or to schedule a free, no-obligation consultation, contact us US Tax Consultants at Tel: +34 915 194 392.
You can learn more about U.S. Tax Consultants online at ustaxconsultants.es, or follow on Facebook at: @USTaxConsultants and Instagram: @ustaxconsultants.
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