Modelo 720
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Modelo 720/721, Assets and Crypto Located Abroad

Informative declarations are one of the modalities of information gathering that consist of the massive supply of tax-related information to the Administration on a periodic basis and through standardized channels.

  • Modelo 720 is the ‘classic’ form. It covers traditional assets like bank accounts, stocks, and real estate.  
  • Modelo 721 is the newer form specifically for virtual currencies (cryptocurrencies) held in foreign exchanges.  

If you’re unsure where to begin, check out our comprehensive tax obligation strategy. Taxes in Spain Guide 2026.

Informative Declaration. Declaration of assets and crypto located abroad exceeding 50,000 Euros, including real estate properties.

  • “Informative Declaration.” This specifies that it is for reporting information, not for paying a tax directly (though penalties for not filing can be severe).
  • “Assets and rights located abroad.” This is a broad category that includes bank accounts, securities, insurance, and real estate in Modelo 720, cryptocurrencies in Modelo 721.
  • Over 50.000 Euros: The filing threshold. You must file if the total value of your declared assets abroad exceeds this amount.

Modelo 720

For Modelo 720, you must file if any of these three categories exceed €50,000 as of December 31st:

  1. Accounts (Bank balances).
  2. Investments (Stocks, bonds, life insurance).  
  3. Real Estate (Foreign property).

Form 720 English
English
Modelo 720 Español
Spanish

📄 Need an official form? > You can download the reference PDF and other tax models in our Spanish Tax Forms Library. We provide summaries and official BOE templates to help you prepare your filing.

Modelo 720 FAQ (Assets Abroad Declaration)

Any More Questions?

Download here the 21-page PDF.

Current Penalties for Modelo 720 Non-Compliance

The current penalties are complex and depend on whether the filing is late or incorrect, and whether it is done voluntarily or after a request from the Tax Agency (AEAT).

⚠️ Additional Major Consequences

The penalties above are administrative fines. The most significant financial risk comes from the possibility of the Spanish Tax Agency treating the undeclared assets as unjustified capital gains (unjustified wealth):

  • Imputed Income: The value of the undeclared asset can be considered as taxable income (unjustified capital gain) for the earliest non-prescribed year, and taxed at the appropriate income tax rate (IRPF).
  • Reduced Statute of Limitations: Following the ECJ ruling, the statute of limitations for the Modelo 720 is now generally four years, instead of being open-ended.
  • Voluntary Correction: Filing the Modelo 720 voluntarily before an investigation begins is critical for minimizing fines and avoiding the presumption of unjustified capital gains.

Model 721: Informative Declaration on Virtual Currencies Located Abroad

This is a very detailed breakdown of the Model 721 requirements from the Spanish Tax Agency. This information is highly valuable for Spanish tax residents dealing with cryptocurrencies.

1. Who is Obligated to File Model 721?

For Modelo 721, the rules are similar but focused on Crypto. If the total value of your crypto held on foreign exchanges (like Binance, Coinbase, or Kraken) exceeds €50,000 on December 31st, you must file.  

Obligation:

  • Individuals who are holders of virtual currencies located abroad.
  • Individuals who are beneficiaries, authorized persons, or otherwise have power of disposal over virtual currencies.
  • Individuals who are the beneficial owners of virtual currencies.

Custody Requirement:

The virtual currencies must be custodied by persons or entities that provide services to safeguard private cryptographic keys on behalf of third parties for the purpose of maintaining, storing, and transferring virtual currencies, as of December 31st each year.

Threshold:

There is no obligation to file if the balances of all virtual currencies held abroad, valued in euros as of December 31st, do not collectively exceed €50,000. If this joint limit is exceeded, information must be provided for all virtual currencies held abroad.

2. What Information Must Be Provided?

The declaration requires the following details for the virtual currencies held abroad:

  • The full name or business name, and tax identification number (if applicable), of the person or entity providing custody services for the cryptographic keys (the custodian), along with their address or website address.
  • The complete identification of each type of virtual currency.
  • The balances of each type of virtual currency as of December 31st, expressed in units of the virtual currency and their valuation in euros.
    • Examples of required identification formats include: Bitcoin (BTC), Ethereum (ETH), Tether USDt (USDT), etc., as they appear on reference cryptographic rating sites like CoinMarketCap.

3. Key Definitions and Scope

TermDefinition and Scope
Virtual CurrencyA digital representation of value not issued or guaranteed by a central bank or public authority, not necessarily associated with a legally established currency, and lacking the legal status of currency or money, but which is accepted as a medium of exchange and can be transferred, stored, or traded electronically.
Situated AbroadVirtual currencies are considered “situated abroad” when the person, entity, or permanent establishment providing custody services for the private cryptographic keys is not obligated to file an informative declaration in Spain.
Custody (Custodial vs. Non-Custodial)The obligation only applies if the virtual currencies are custodied by a third party. If the holder maintains control of the private cryptographic keys (e.g., in a non-custodial or “cold wallet”), the assets are NOT considered custodied by a third party, and they should not be counted toward the €50,000 reporting threshold for Model 721.

The “Cold Wallet” Exception

This is where Modelo 721 gets interesting. The law specifically targets crypto held in custody—meaning someone else (an exchange) is holding the keys for you.  

If you use self-custody—like a hardware ‘cold wallet’ (Ledger, Trezor) or a private software wallet where you hold the private keys—you generally do not have to file Modelo 721. Why? Because technically, those assets aren’t ‘held abroad’ by a third party; they are in your personal possession. However, be careful: if you move that crypto back to an exchange before December 31st and it’s worth over €50k, the obligation returns!

4. Filing Deadline

  • Deadline: Model 721 must be filed between January 1st and March 31st of the year following the year to which the information refers.

In Summary (Two Primary Requirements for Filing):

  1. The virtual currencies must be custodied by a third party providing services to safeguard the cryptographic keys (i.e., held in a custodial wallet or on an exchange).
  2. That custodial entity must not be a resident in Spain or a permanent establishment in Spanish territory.

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