# Modelo 720: Spain's Foreign Asset Declaration > Spain's Modelo 720 explained: €50,000 threshold per asset block, March 31 deadline, post-ECJ penalties under Ley 5/2022, Modelo 721 for crypto. Author: Мария Плотникова — юрист, Family Office (https://wiki.private.law/authors/plotnikova) Last modified: 2026-07-16T09:46:00.000Z Canonical: https://wiki.private.law/en/modelo-720 Topics: investments Jurisdictions: spain Semantic tags: crypto-friendly --- Spain is one of the few countries where a tax resident must file a separate annual information return on assets held abroad. Modelo 720 creates no tax by itself — it is pure compliance — yet for a decade it sat at the centre of Europe's loudest tax dispute: draconian penalties, a CJEU ruling and the 2022 reform. Data as of July 2026. ## Who files and what is reported The obligation applies to Spanish [tax residents](https://wiki.private.law/en/tax-residency-basics) under the general IRPF regime. The threshold is €50,000 — assessed not across all assets combined but per each of three independent blocks ([AEAT](https://sede.agenciatributaria.gob.es/Sede/procedimientoini/GI34.shtml)): | Block | Covers | Threshold | | --- | --- | --- | | 1. Accounts | Accounts with foreign banks | €50,000 | | 2. Securities and rights | Securities, shares, rights, insurance policies, annuities | €50,000 | | 3. Real estate | Foreign real estate and rights over it | €50,000 | The filing window runs from January 1 to March 31 of the year following the reporting year: for 2025, the deadline was March 31, 2026. Electronic filing only. A repeat filing is required only when a block has grown by more than €20,000 since the last return filed, or when previously declared positions were closed or disposed of ([AEAT FAQ](https://sede.agenciatributaria.gob.es/Sede/todas-gestiones/impuestos-tasas/declaraciones-informativas/modelo-720-decla_____sobre-bienes-derechos-extranjero_/preguntas-frecuentes/forma-calcular-limite-que-obliga-declarar.html)). Crypto assets sit outside Modelo 720: since reporting year 2023 they are declared on a separate Modelo 721 — same €50,000 threshold, same March 31 deadline. > 🍓 Modelo 720 is an information return, not a tax: €50,000 per block, filed by March 31. Penalties became moderate after the 2022 reform, but the obligation itself is fully alive — and AEAT cross-checks filings against CRS data automatically. ## Penalties: before and after the CJEU The old regime was punitive: a 150% surcharge on the assessed tax, fixed €5,000 fines per undisclosed data item, and imprescriptibilidad — undeclared assets could be imputed as income with no statute of limitations. On 27 January 2022 the Court of Justice of the EU held in [C-788/19](https://www.escura.com/en/the-court-of-justice-of-the-european-union-has-delivered-its-judgement-concerning-the-penalty-regime-for-the-informative-return-on-assets-and-rights-located-abroad-form-720-finding-it-contrary-to-eu/) that this construction breached the free movement of capital. [Ley 5/2022](https://bm.consulting/en/insights/modelo-720-spain-ecj-ruling-reform-complete-guide-2026/) of 9 March 2022 normalised the regime: the special fines and imprescriptibilidad were repealed, and undeclared gains can now be assessed only within the general four-year limitation period of the LGT. Penalties paid under the old regime were recovered through [revocación](https://www.ruizballesteros.es/en/revocation-of-penalties-for-form-720/). What applies now is the general penalty regime of articles 198–199 LGT. The figures below are indicative — exact amounts depend on how the breach is qualified; check the [AEAT FAQ](https://sede.agenciatributaria.gob.es/Sede/en_gb/todas-gestiones/impuestos-tasas/declaraciones-informativas/modelo-720-decla_____sobre-bienes-derechos-extranjero_/preguntas-frecuentes/sanciones-efectos.html). | Scenario | Penalty | | --- | --- | | Old regime (repealed 2022) | 150% surcharge + €5,000 per item, no limitation period | | Late filing before any AEAT request | ~€10 per data item, min €150, max €10,000 per block | | After a request / inaccurate data | €20 per item, min €300, max €20,000 | ## Where practice stands in 2026 The CJEU struck down the sanctions, not the declaration. AEAT actively matches returns against CRS feeds: a resident's foreign account is visible to the tax office with or without a 720. A missed filing today means a moderate fine, not a disaster — the standard move is voluntary late filing before AEAT issues a formal request. A separate angle is the [Beckham regime](https://wiki.private.law/en/beckham-law). Its beneficiaries are formally residents but are taxed under IRNR rules, so residents' information duties do not reach them: no 720, no 721, no worldwide [wealth tax](https://wiki.private.law/en/spain-wealth-tax) return. The obligation switches on from the first year after the regime ends, together with worldwide IRPF — which is why the [exit from the regime](https://wiki.private.law/en/beckham-law-exit) deserves planning in advance. ## FAQ ### **Is Modelo 720 filed every year?** No. A new filing is due only when a block has grown by more than €20,000 since the last return, or when previously declared positions were closed or sold. ### **Is the €50,000 threshold assessed across all assets combined?** No — per block. A €30,000 account plus a €40,000 property trigger nothing; assets aggregate only inside each block. ### **What happens if I file late now?** General LGT fines with €150–300 minimums, not the old 150% surcharge — plus ordinary assessment of any undeclared income within the four-year limitation period. ### **Do Beckham regime holders file Modelo 720?** No — not for the entire life of the regime. The duty starts with the first year on the general IRPF after the regime ends. ### **Where does a foreign brokerage account go?** Securities and rights form the second block, assessed separately from the bank accounts block. --- ## FAQ ### Is Modelo 720 filed every year? No. A new filing is due only when a block has grown by more than €20,000 since the last return, or when previously declared positions were closed or sold. ### Is the €50,000 threshold assessed across all assets combined? No — per block. A €30,000 account plus a €40,000 property trigger nothing; assets aggregate only inside each block. ### What happens if I file late now? General LGT fines with €150–300 minimums, not the old 150% surcharge — plus ordinary assessment of any undeclared income within the four-year limitation period. ### Do Beckham regime holders file Modelo 720? No — not for the entire life of the regime. The duty starts with the first year on the general IRPF after the regime ends. ### Where does a foreign brokerage account go? Securities and rights form the second block, assessed separately from the bank accounts block. --- ## Factual claims - The filing window runs from January 1 to March 31 of the year following the reporting year: for 2025, the deadline was March 31, 2026. - Crypto assets sit outside Modelo 720: since reporting year 2023 they are declared on a separate Modelo 721 — same €50,000 threshold, same March 31 deadline. - The old regime was punitive: a 150% surcharge on the assessed tax, fixed €5,000 fines per undisclosed data item, and imprescriptibilidad — undeclared assets could be imputed as income with no statute of limitations. - Ley 5/2022 of 9 March 2022 normalised the regime: the special fines and imprescriptibilidad were repealed, and undeclared gains can now be assessed only within the general four-year limitation period of the LGT. - What applies now is the general penalty regime of articles 198–199 LGT.