Who Has to File Modelo 720?
Modelo 720 is an informational return — it does not create any additional tax by itself — that Spanish tax residents must file to report assets and rights held abroad. Nationality is irrelevant: a British, American, Dutch or Latin American national who has become tax-resident in Spain has exactly the same obligation as a Spanish citizen.
You are generally a Spanish tax resident if any of these apply:
- You spend more than 183 days of the calendar year in Spain.
- Your main base of economic activities or interests is in Spain.
- Your spouse and dependent children habitually reside in Spain.
New arrivals often overlook this in their first full year of residency, when foreign accounts and brokerage portfolios built up before moving to Spain suddenly fall within scope.
The Three Categories and the EUR 50,000 Threshold
Modelo 720 splits foreign assets into three independent categories, each with its own EUR 50,000 threshold measured at 31 December:
| Category | What it covers | Value reported |
|---|---|---|
| C1 — Accounts | Current, savings and deposit accounts at foreign banks; uninvested broker cash | Balance at 31 Dec + Q4 average balance |
| C2 — Securities | Shares, ETFs, funds, bonds, options, life insurance held abroad | Market value at 31 Dec |
| C3 — Real estate | Property and land located outside Spain | Acquisition value |
Per category, not global
The EUR 50,000 threshold is tested separately for each category. EUR 40,000 in a foreign account plus EUR 40,000 in shares does not add up to EUR 80,000 — neither category crosses its threshold, so no filing is due.
One point that regularly catches expats out: what matters is where the custodian sits, not where the company is incorporated. UK or US shares held through a foreign broker are reported; even Spanish shares held through a foreign broker fall in category C2.
Deadline and How to File
Modelo 720 for tax year 2026 must be filed between 1 January and 31 March 2027. It is filed electronically through the Agencia Tributaria (AEAT) electronic office using a digital certificate, DNIe or Cl@ve PIN. Unlike the income-tax return (which runs April to June), the 720 window is earlier and shorter, so many people discover the obligation too late.
For foreign-currency assets you must convert to euros using the official European Central Bank (ECB) rate at 31 December — not your broker's rate. AllInvestView applies these ECB rates automatically across every position.
Do You Have to File Every Year?
No. After your first filing, you only need to file again for a category if:
- Its value has increased by more than EUR 20,000 over the last value you declared (a “modification”, key M), or
- You have closed the position and no longer hold it at 31 December (a “cancellation”, key C).
So a portfolio that stays comfortably above EUR 50,000 but drifts only a little year on year generally needs no new filing. The calculator above applies this rule for you.
Penalties After the 2022 EU Court Ruling
Modelo 720 was historically notorious for a punitive penalty regime — fines of 150% of undeclared value and effectively no statute of limitations. On 27 January 2022 the Court of Justice of the EU ruled that regime disproportionate and contrary to the free movement of capital.
Today the ordinary General Tax Law penalties apply instead:
- EUR 20 per data item or set of items, with a minimum of EUR 300 and a maximum of EUR 20,000 (art. 198 LGT),
- halved (EUR 10 per item, minimum EUR 150) if you file late voluntarily, before any request from the tax authority, and
- the normal four-year limitation period.
Still mandatory
The disproportionate fines are gone, but Modelo 720 remains a legal obligation. Spain exchanges financial-account data automatically with more than 100 countries (CRS), so foreign holdings are visible to the AEAT. If you find out late, filing after the deadline is better than not filing at all.
Frequently Asked Questions
Yes. The obligation is based on tax residency, not nationality. If you are tax-resident in Spain and your foreign assets exceed EUR 50,000 in any of the three categories at 31 December, you must file — whatever passport you hold.
If you became a Spanish tax resident for that year (typically by spending more than 183 days in Spain), then yes, your foreign assets at 31 December are in scope. Your first year of residency is the most common time to have a Modelo 720 obligation you did not expect.
Generally yes. Foreign bank and brokerage accounts, pensions held as accounts, and securities held with foreign custodians are reported under the relevant category once it crosses EUR 50,000. Wrappers like ISAs are tax-free in the UK but are not recognised as exempt for Spanish purposes, so the underlying assets still count. Confirm the exact classification of pension products with a Spanish adviser.
The official ECB reference rate at 31 December of the tax year. Your broker's rate, Google's rate or the forex mid are not accepted. AllInvestView downloads and applies the ECB rates automatically.
No. Modelo 720 covers accounts, securities and real estate. Crypto held on foreign platforms is reported separately on Modelo 721 (in force since 2024). If you hold both, you may need to file both returns.