- Modelo 720 reports to AEAT three types of property abroad: Bank accounts (article 42 bis Real Decreto 1065/2007), securities, insurance and rents (42 ter), real estate (54 bis) I check the 50,000 threshold for each type separately [1].
- The Spanish tax residents are serving. The circle is wider: Commissioners, beneficiaries, persons with the right of disposal and final owners (titular real). If you own the asset during the year but have broken up with it by 31 December, the information is still supplied. [1].
- Submission window: January 1st to March 31st, following the report. For assets as at 31 December 2026, AEAT indicated a window through 31 March 2026, with a technical malfunction extending for four calendar days [1][6].
- No annual payment is required. A new declaration is needed when the group's cost has increased by over 20,000 me by the last one, or when you're no longer the owner. [1].
- Modelo 720 does not replace the modelo 100. Modelo 100 considers IRPF tax on year's income, modelo 720 only informs of assets. [1][5][11].
- Fines following the decision of the EU Court of Justice of 27 January 2022 (C-788/19) and Law Ley 5/2022: Special fine 5,000 I for data and 150 per cent for unconfirmed increases removed, common articles 198 and 199 Ley 58/2003 are applicable separately for each of the three groups [3][4][8].
What is a modelo 720 in simple words
Modelo 720 is a report for the tax service (AEAT) that the Spanish tax resident has a foreign identity. The full title of the form is: "Declaración informativa sobre bienes y derechos situados en el exranjero." It combines three separate duties: to report on foreign bank accounts, securities, insurance and rents, real estate. 54 bis Real Decreto 1065/2007, approved Orden HAP/72/2013 [1][2][9].
The tax declaration itself does not create: AEAT states that this duty is not tied to any particular tax [7]The tax on the income from these assets, for example, interest or lease, is considered as a modelo 100 [10]The crypthalates are not included: for virtual currencies, there is a separate form of modelo 721 [9].
Who is required to serve the module 720
The duty depends on the tax residence, not the type of residence permit, and is granted by the tax residents: natural and legal persons, permanent missions of non-residents and education under article 35.4 LGT. For a person, residence is determined by article 9 Ley 35/2006: more than 183 days in the calendar year or the main centre of economic interests in Spain, plus a family presumption. [1][10]I'll give you more details: Tax residence in Spain.
The circle of owners who are more than required to do so is to be presented by the authorized persons, beneficiaries, account holders and final owners on Ley 10/2010. [1].
Businesses and companies that keep a Códico de Comercio account and record these assets individually do not serve (article 42 bis, 4.c, and similar items) [1]Parties to the special regime of article 93 Ley 35/2006 (Beckham's law) to explain AEAT do not file a declaration, because they do not pay tax on all world income. Their family members are not automatically released: they file if they are tax residents and exceed the [7].
Three asset groups and threshold Euro50,000
| Group | What goes in | What counts for the threshold | Article |
|---|---|---|---|
| Foreign bank accounts | Current, savings, term deposits, credit accounts and other cash accounts | The balance at 31 December for all accounts together and the average balance of the last quarter together, just over any of the two. | 42 bis [1] |
| Securities, rights, insurance, rents | Foreign companies ’shares and shares, bonds, fund equity, life and disability insurance from foreign insurers, rents | Total value under the Property Tax Act (Ley 19/1991) | 42 ter [1] |
| Real property | Real property and rights abroad, including time-sherling, unfruct, bare property | Cost of acquisition and value of rights | 54 bis [1] |
The threshold of 50,000 is applied separately to each group. If exceeded, the declaration includes all assets of that group, not one excess. [1]The accounts do not need to be reported if neither the balance as at 31 December nor the average balance for the last quarter is more than 50,000 y [1]. The accounts group excludes those opened in foreign branches of Spanish banks and already reported by the bank (art. 42 bis, 4.d) [1].
Deadline and how to submit in future years
The application is filed from 1 January to 31 March of the year following the report. For assets as at 31 December 2026, AEAT indicated a window from 1 January to 31 March 2026. If online service is not possible for technical reasons, four more calendar days are allowed. [6]B. You can file or file [9]The asset window as at 31 December 2026 AEAT on 2 October 2026 has not yet been published: 42 bis, 42 ter and 54 bis again 1 January-31 March 2027 [1].
A re-entry is needed if the group's value has increased by more than 20,000 me to the last one, and the accounts compare both figures, the balance and the average balance. [1]If you become a tax resident in the middle of the year, IRPF is still a calendar period, and the liability for that year is estimated to be 31 December, the first year's nuances are based on dates, it's a question for the tax consultant.
Modelo 100 and Modelo 720: What's the difference
Modelo 100 is the annual IRPF declaration (Impuesto sobre la Renta de las Personas Físicas), which considers the tax on the income of the calendar year and receives the amount to be paid or recovered. [1][11].
| Parameter | Modelo 100 | Modelo 720 |
|---|---|---|
| What is it? | IRPF Annual Declaration | Information statement on assets abroad |
| Outcome | Tax on payment or refund | Just the information, no tax. |
| Period 2026 | 8 April to 30 June (income 2025) | 1 January to 31 March (assets at 31.12.2025) |
| Threshold | Depends on the type and amount of income (art. 96 Ley 35/2006) | 50,000 I per group |
Table data: [1][5][6][11]If a foreign account is below the threshold, the modulo 720 is not required in the accounts but interest on it remains part of the resident ’s global income in modelo 100 (article 2 Ley 35/2006) [5]Who is entitled to a deduction for international double taxation shall in any event give a modelo 100 (art. 96.4) [5]As a single income tax, two countries: Double taxation Russia and Spain.
Party to the regime of article 93 Ley 35/2006 (modelo 149threshold, file an annual return on the modelo 151 instead of the modelo 100, and the modelo 720 does not file [7].
What changed after the EC Court ruling and Ley 5/2022
In judgement of 27 January 2022 in case C-788/19, the Court of Justice of the EU (Tribunal de Justicia de la Unión Europe) found certain elements of the Spanish Modelo 720 regime incompatible with EU law [3]Spain responded by Law Ley 5/2022 of 9 March 2022 and rewritten additional regulation 18 LGT (which left a list of information), amended article 39 Ley 35/2006 on unconfirmed increases and repealed additional regulations 1 and 2 Ley 7/2012 [3][5].
| Question | Until 2022 | Now. |
|---|---|---|
| Fine for non-reporting or inaccurate data | Special scale: e.g. 5,000 me for every count, at least 10,000 me, very serious violation [4] | General regime of articles 198 and 199 LGT [2][8] |
| Unconfirmed gains in assets | Failure to file a declaration in time resulted in assets being considered unconfirmed gains in the oldest of the unliquidated periods (art. 39.2) [4] | The increase relates to the period in which it was discovered if the taxpayer fails to prove possession from the date until the statute of limitations (art. 39.1) [5] |
| Special penalty for unconfirmed increase | 150 per cent fine on the tax on such increases (additional provision 1 Ley 7/2012) [4] | Rescission of Ley 5/2022 [3] |
How the new rules apply to declarations of past years depends on the circumstances of the case.
What fines are in effect now?
AEAT states that after Ley 5/2022, articles 198 and 199 LGT and articles 14 and 15 Real Decreto 2063/2004 are in force, and sanctions are considered independently for each of the three obligations [8]This general rule, as the inspection will apply in your case, is determined by the tax consultant.
| Violation | LGT authorization |
|---|---|
| Not filed on time | 20 I for every data set or data set, not less than 300 I and not more than 20,000 I (art. 198.1) [2] |
| Late filed without request from AEAT | Half of these amounts and limits (article 198.2) [2] |
| Submitted incomplete or inaccurate, in monetary terms | Up to 2% of the amount of undeclared or incorrect data, not less than 500 y (Article 199.5) [2] |
What is considered "data" and "dataset" by the legislator is defined in articles 42 bis, 42 ter and 54 bis itself: for accounts, the data set is the bank and the account, the date and each balance [1].
What to prepare in advance: a checklist for customers from Russia and the CIS
- List of all accounts abroad, including brokering and storage, with opening and closing dates, 31 December balance and average balance for the fourth quarter.
- Securities and fund equity statements, insurance documents with a purchase price and rent.
- Foreign real estate: address, date and value of acquisition, if sold within a year, value and date of sale.
- Documents that confirm that you were a beneficiary, an authorized person or a title holder, unless you were the sole owner.
As the text of article 42 bis does not specify how to count the residues in rubles, tenge, Belarusian rubles, hryvnias and other currencies in euros. [1]Please specify the order of the hestor before filling out the form.
Typical Errors
- Count the threshold on the total assets. It is considered separately for each of the three groups. [1].
- Do not file a declaration because the balance is below 50,000 I on 31 December, but the average balance for the fourth quarter is higher. [1].
- Forget the account closed during the year. [1].
- Forget that the beneficiary or commissioner of another's account also serves [1].
- Consider that the modulo 720 replaces the income statement or vice versa [10].
- Include cryptivates in the modelo 720: for them modelo 721 [9].
- Targeting the old 5000 and 150 % fine materials: after Ley 5/2022, another mode [3][4].
When Individual Review Is Needed
A review is needed if you have become a tax resident in the middle of the year, if accounts and assets in several countries, if you are a beneficiary of a foreign account or property in common property, if you have not previously filed an asset declaration above the threshold or choose a regime of article 93. What exactly is the filing and in what assessment is determined by the tax consultant.
What can we help you with?
The NEXO team in Barcelona is helping to collect a list of foreign assets, receipts and documents, prepare questions for the tax consultant and link this statement to the rest of the tax transfer. First consultation: 30 minutes free, full consultation: 121 in 45 minutes. ConsultationIII. Service page: Digital nomad ’s residence permit, step by step: DNV route sheet.
Frequent issues
What is a modelo 720 in Spain?
How does a modelo 720 differ from a modelo 100?
Do you need to apply for a permit to a foreigner?
How much do you need to pay the module 720?
When do you serve the module 720?
Should you serve a module 720 every year?
What happens if you don't give the modelo 720?
Do they serve a modelo 720 in Beckham mode?
Based on source
- BOE · Real Decreto 1065/2007, articles 42 bis, 42 ter and 54 bis .
- BOE · Ley 58/2003 (LGT), additional provision 18 and articles 198, 199 .
- BOE · Ley 5/2022, preamble, additional cancellations, disprofiions finales cuarta and quinta ♪
- BOE · Ley 7/2012, original text (disposions adicionales 1 and 2, article 3 and DA 18 LGT 2012 revision)
- BOE · Ley 35/2006 (LIRPF), articles 2, 9, 39 and 96 as drafted
- AEAT · Modelo 720: Date of submission (updated 08.09.2026) ♪
- AEAT · Modelo 720: Questions and answers by the person who is required to submit (updated 08.09.2026)
- AEAT · Modelo 720: Questions and Answers,sancions y efectos (updated 08.09.2026)
- AEAT · Modelo 720: the procedure page (Orden HAP/72/2013, form, model 721)
- AEAT · Folleto: residents facts en España con Rentas proceedings de Russia (section on foreign asset information) ♪
- AEAT · Manual práctico de Renta 2025: plazo y forma de presentación del modelo 100 ↗
Sources are viewed on 02.10.2026. Consolidated texts and departmental reference pages are informative: legal application takes into account official publications, changes and specific circumstances. Material has not been personally checked by counsel.
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The source is viewed on 02.10.2026 · NEXO · Drafting Draft · Sources do not replace individual legal advice.

