Who must declare foreign assets (Modelo 720) and when

Key rules

• Threshold: Each of the three categories is tested separately against 50,000 EUR.
• Filing window: You file online from 1 January to 31 March of the year after the year you report.
• Filing again: You file again for a category only if it rises by more than 20,000 EUR or you sold or closed a declared asset.
• Beckham regime: You do not file while you are under the Beckham regime, but you must once you leave it.
• Penalties: The EU ruling removed the 150% fine, but ordinary fines still apply for not filing.

Do you have to file?

You must file if you are a Spanish tax resident and your assets abroad in any one category are worth more than 50,000 EUR. This applies to individuals and to companies. It does not apply to non-residents.

It does not matter how you hold the asset. You count if you are the owner, a beneficiary, an authorised person on the account, someone with power to dispose of it, or the effective owner (titular real). Being a signatory on a foreign account can therefore bring you in, even if the money is not yours.

The three categories

Each category is tested on its own. Being under the limit in one does not excuse another.

1. Accounts at banks and other financial institutions abroad: current, savings, deposit and credit accounts.
2. Securities, insurance and annuities held with foreign entities: shares and holdings, fund units, other equity, life or disability insurance, and temporary or lifetime annuities.
3. Real estate and rights over real estate abroad, including timeshare rights.

Add up the value in each category. If one total is above 50,000 EUR, declare every asset in that category, including the small ones. The checklist below walks you through the sums, and the calculator lets you test your totals.

What is exempt

You do not need to declare:

• assets located in Spain
• assets in a category that stays at or below the limit
• assets the Spanish tax authority already knows about through other filings
• accounts held by diplomatic or consular staff abroad

Companies that record the assets in their own Spanish books, and certain public bodies, are also excluded. If you think an exemption applies to you, check it with a tax adviser before relying on it.

If you are under the Beckham regime

While you are taxed under the Beckham regime, you do not file, even though you are a Spanish tax resident. Once you leave the regime, the duty applies from then on, subject to the same limit.

When to file

You file online between 1 January and 31 March of the year after the year you are reporting. Assets held in 2025 are reported by 31 March 2026. The filing steps are in the process below.

When to file again

After your first declaration, you do not file every year. You file again for a category only if its value rises by more than 20,000 EUR over the last declared value, or if you sold or closed a declared asset. The test is per category, and you compare against the value in your last declaration for that category. The question below the page helps you decide, and the section on closing or selling an asset covers that case.

What happens if you do not file

The duty to file is still in force. In 2022 the EU's top court found the old regime broke EU free-movement rules. Spain then repealed the special 150% fine and the rule that treated unreported assets as unjustified gains with no time limit.

Ordinary penalties still apply. They are a fixed 5,000 EUR per data item, with a minimum of 10,000 EUR, for failing to file, and lower amounts for filing late. Normal time limits now apply. Do not assume the ruling means you can skip the declaration.

Choosing between options

Do you need to file a new Modelo 720 for a category you declared before?

• Do not file again: The category's value rose by 20,000 EUR or less over the last declared value, and you sold or closed nothing declared.

Test each category separately against the value in its last declaration: file again only if it rose by more than 20,000 EUR or you sold or closed a declared asset.

Filing the foreign asset declaration step by step

• Get a way to identify yourself online: an electronic certificate (such as the FNMT certificate), the electronic DNI or Cl@ve PIN: before the filing window opens

• Or authorise a tax adviser or representative to file for you with a power of attorney or an authorisation registered with the tax agency: before you start, if you do not file yourself

• Open the Modelo 720 procedure on the electronic office of the AEAT, Spain's tax agency, and identify yourself: from 1 January Deadline: 31 March.

• Choose a new declaration and enter the year you are reporting: after you log in

• Enter your own details as the declarant: next

• Add each asset under its category: accounts (code 1), securities, insurance and annuities (code 2), real estate (code 3): after your details

• If you have many entries, upload a text file in the official record layout instead of typing line by line, and fix any errors the upload reports: instead of entering each line

• Check the totals, confirm, sign and submit: once all entries are in

• Save the receipt, which carries a secure verification code: right after submitting

• To correct a filed declaration, file a new one for the same year marked complementary (adds missing data) or substitutive (replaces the whole earlier one), giving the number of the declaration you correct: as soon as you spot a mistake

Checklist

• Add up the value of your foreign accounts, then your securities and insurance, then your foreign real estate, as three separate totals.

• Compare each total with 50,000 EUR and mark every category that is above it.

• Put the filing window of 1 January to 31 March in your calendar for the year after the year you are reporting.

• If you have filed before, compare each category with the value in your last declaration for it.

• Do not rely on the old 150% fine or the rule with no time limit; both were repealed in 2022, but the duty to file remains.

What if you closed or sold a foreign asset during the year?

Selling or closing a declared asset means you file again. A rise of more than 20,000 EUR in a category also means you file again. Smaller changes do not.

When you must file again

After your first Modelo 720, you file a new one for a category only in these cases:

• You sold, closed or transferred an asset you had declared. You file for that category in the year it happens, to report that you no longer hold it. This applies even if what is left in the category is below the 50,000 EUR threshold.

Each category is tested on its own. A rise in one category does not force you to refile the others.

When you do not need to file again

If nothing was sold or closed and no category rose by more than 20,000 EUR, you file nothing for that year. Values that fall, or rise by less than that amount, do not trigger a new declaration.

If you closed an account

You report the closure if you were previously required to declare that account. The balance is the one on the day the account was cancelled. The average balance is worked out from the start of the last quarter up to that date.

What to watch for

• Compare each category with the value in your last filed declaration, not with last year's actual value. Several small rises can add up to more than 20,000 EUR over the years.
• Keep the closing or sale paperwork. You need the cancellation or sale date and the balance or value on that day.

Check whether your foreign assets cross the reporting thresholds

Work it out

What you enter

• Total balance of your foreign accounts on 31 December (EUR): Your bank statements or app, balance on 31 December, added up across all foreign accounts.
• Average balance of those accounts over the last quarter (EUR): Your bank app or statements, average balance from 1 October to 31 December (or to the closing date).
• Total value of foreign shares, funds, insurance and annuities (EUR): Your broker, fund or insurer's year-end statement.
• Total value of foreign property (your share) (EUR): The purchase deed or purchase contract, using your ownership share of the acquisition value.
• Value of one category in your last declaration (EUR): Your previous Modelo 720 receipt for that category.
• Value of that same category now (EUR): Your latest statements for that category.

Figures used

• Threshold per category: 50,000 EUR
• Increase that triggers a new declaration: 20,000 EUR

Worked example (with Total balance of your foreign accounts on 31 December 42,000 EUR, Average balance of those accounts over the last quarter 58,000 EUR, Total value of foreign shares, funds, insurance and annuities 30,000 EUR, Total value of foreign property (your share) 120,000 EUR, Value of one category in your last declaration 55,000 EUR, Value of that same category now 79,000 EUR)

When the sum misleads

• Any figure above zero in the first three results means you declare that whole category, not only the excess.
• A zero in one category does not excuse another: each category is tested on its own.
• For joint holdings, use your own share, and test the threshold for yourself separately from the other holders.
• For an account closed during the year, use the balance on the closing date and the average from the start of the quarter to that date.
• A result of zero in the last figure means no new declaration for that category, unless you sold or closed a declared asset.

Frequently asked questions

Do I have to file Modelo 720 if I am under the Beckham regime?

No, you do not have to file Modelo 720 while the Beckham regime applies to you, because you are taxed as a non-resident on Spanish income. Once you leave the regime, you must file if a category is above the threshold.

Which foreign assets are exempt from Modelo 720?

Assets located in Spain, assets already known to the tax agency through other filings, and assets held by Spanish-registered entities are exempt. Accounts held abroad by diplomatic or consular staff are also exempt, as are categories below the threshold.

Can I still be fined for not filing Modelo 720 after the EU court ruling?

Yes, the duty to file remains, and late or missing filings still bring ordinary fines. The old 150% special fine and the rule with no time limit were repealed in March 2022. A failure to file can cost 5,000 EUR per data item, with a minimum of 10,000 EUR.

Does being a signatory on a foreign account count for Modelo 720?

Yes, you must include an account if you are an authorised person or have power of disposal over it, not only if you own it. The same goes for being a beneficiary or effective owner of foreign accounts, securities, insurance or property.