Form 720: when you must report the assets you hold outside Spain
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If you are tax resident in Spain and hold bank accounts, securities, funds, insurance or property in another country, you may have to report them to the Spanish Tax Agency on form 720 (modelo 720), even if they produce no income. Grupo Avanza Consultores, tax and accounting adviser in Paterna (Valencia), checks whether you are obliged and for which blocks, prepares and files the return and, if it was not filed on time, prepares the late filing. We work remotely and reply in writing in English, with a quote before we start.
Who has to file it
Individuals and legal entities resident in Spain (article 2 of Order HAP/72/2013), not only as owners: also anyone who appears on an account as authorised person, beneficiary or with power of disposal, and anyone who is the beneficial owner under the anti-money-laundering law (additional provision eighteen of the General Tax Act). The return has three independent blocks: accounts with financial institutions located abroad (article 42 bis of the Regulations approved by Royal Decree 1065/2007); securities, holdings in investment funds, life or disability insurance and annuities (article 42 ter); and real estate and rights over real estate (article 54 bis). There are exceptions for what is recorded individually in the accounts of resident legal entities and, for accounts and real estate, of individuals carrying on a business who keep accounts under the Commercial Code (articles 42 bis.4, 42 ter.4 and 54 bis.6).
From which amounts
Each block is measured separately and with its own value. For accounts, you must file if the balance at 31 December or the average balance of the last quarter, adding all accounts together, exceeds 50,000 euros (article 42 bis.4.e). For securities, funds, insurance and annuities, if their combined value, calculated under the Wealth Tax rules, exceeds 50,000 euros (article 42 ter.4.c and 6). For real estate, if the combined acquisition value exceeds 50,000 euros; for timeshares and for usufruct or bare ownership, the value at 31 December under the Wealth Tax rules counts (article 54 bis.3, 4 and 6.d). Once a block exceeds its limit, every asset in that block is reported.
Deadline and later years
It is filed between 1 January and 31 March of the year after the one the information refers to. In later years you only file again if the combined value of a block has increased by more than 20,000 euros over the value that triggered the last return, or if during the year you stopped holding an asset already reported, for example by closing an account or selling a property (articles 42 bis.5, 42 ter.5 and 54 bis.7).
Your first year in Spain
If you are already tax resident in the year you arrive, under article 9 of the Personal Income Tax Act, your first form 720, if any block exceeds the limit, is for that year, with the position at 31 December, filed between January and March of the following year. Anyone who has opted for the special regime for workers posted to Spain (Beckham Law) is not obliged to file it, according to the Spanish Tax Agency’s frequently asked questions; the same questions state that this does not extend to the rest of the family, so a spouse and children resident in Spain who do not apply the regime themselves may be obliged; if they also apply it (article 93.3 of the Personal Income Tax Act), their case is looked at separately.
If it was not filed on time
Since 11 March 2022 form 720 has no penalty regime of its own: Law 5/2022 removed the one in additional provision eighteen, and the general offences of the General Tax Act apply. Failing to file on time, where there is no financial loss to the Treasury, is penalised with 20 euros for each item or set of items relating to the same person or entity, with a minimum of 300 and a maximum of 20,000 euros, and the penalty and its limits are halved if it is filed late without a prior request from the Tax Agency (article 198.1 and 2). Filing it incomplete, inaccurate or with false data is penalised under article 199.
Assets whose holding does not match the income or wealth declared are treated as unjustified capital gains and included in the general taxable base of the tax period in respect of which they are discovered, unless you prove you held them since a date before the limitation period (article 39 of the Personal Income Tax Act). That is why, before a late filing, it is worth gathering proof of when you acquired each asset.
What it is not
It is an information return: the interest, dividends, rents or gains those assets produce are declared in the income tax return. Virtual currencies located abroad and held by a provider that keeps the private keys on behalf of others do not go on form 720 but on form 721, approved by Order HFP/886/2023.
What we do
We check whether you were resident in the relevant year, which blocks exceed the limit and with which values, and we prepare and file form 720 with your authorisation. In later years we check whether it has to be filed again. If it was not filed, we put together the proof of when each asset was acquired and prepare the late filing and any income tax returns that need correcting, as explained in our guide to overdue tax returns in Spain.
Official sources
Additional provision eighteen of Law 58/2003, General Tax Act (wording in force since 11 March 2022, given by the fourth final provision of Law 5/2022), and articles 198 and 199 of that Act; article 39 of Law 35/2006 on Personal Income Tax (in force since 11 March 2022); articles 42 bis, 42 ter (wording in force since 25 April 2023) and 54 bis of the Regulations approved by Royal Decree 1065/2007; Order HAP/72/2013, articles 1 to 3 (article 2 in force since 1 November 2023). Consolidated texts in the Spanish Official Gazette (BOE), consulted on 23 October 2026.
Spanish Tax Agency: compilation of frequently asked questions on form 720 updated to 11 March 2022, questions 1, 4, 65, 66 and 67 (consulted on 23 October 2026).
Frequently asked questions
About form 720
Do I have to file it even if my accounts pay no interest?
Yes, if the limit is exceeded. The obligation depends on the balance at 31 December or the average balance of the last quarter of all your accounts abroad exceeding 50,000 euros together, not on whether they produce income (article 42 bis.4.e of the Regulations approved by Royal Decree 1065/2007).
Do I have to file it every year?
No. After the first return, only if the combined value of a block has increased by more than 20,000 euros over the value that triggered the last return, or if you stopped holding an asset already reported (articles 42 bis.5, 42 ter.5 and 54 bis.7 of the Regulations).
Does someone under the Beckham Law file it?
No, according to the Spanish Tax Agency’s frequently asked questions (question 4): anyone who has opted for the special regime for posted workers is not obliged, and this does not extend to the rest of the family. A spouse and children resident in Spain who do not apply the regime themselves may be obliged.
What happens if I did not file it?
Since 11 March 2022 the general regime applies: 20 euros per item or set of items, with a minimum of 300 and a maximum of 20,000 euros, with the penalty and its limits halved if filed late without a prior request (article 198 of the General Tax Act). It is also worth proving when you acquired each asset (article 39 of the Personal Income Tax Act).
Services
Related guides
Check form 720 before March
Tell us since which year you have been resident in Spain, in which countries you hold accounts, securities, insurance or property, and whether you have filed a form 720 before. We tell you which blocks apply to you and agree the scope and fee before we start. We reply in writing, in English.