Modelo 720 is the form Spain uses to make tax residents, including expats, report assets held outside Spain. If you are a Spanish tax resident and the accounts, investments, insurance policies or property you hold abroad are worth more than 50,000 euros in any one of three categories, you generally have to file an information return between 1 January and 31 March of the following year. For British expats who have moved to Spain from the UK, the UAE or elsewhere, that can include UK bank accounts and ISAs, UK shares and funds, investment policies held offshore and a UK home or rental property. The form does not itself create a tax bill, but failing to file it or filing it incorrectly can lead to penalties, any undeclared income or gains can still be taxed under the ordinary rules, and the return gives the Spanish tax agency a detailed picture of your wealth abroad, and the penalty regime changed significantly in 2022. This guide explains who must file, what is reported, how the thresholds work, the current penalties, the separate Modelo 721 return for cryptoassets held abroad, and the points to plan around. It is general information, not personal tax advice. Spanish rules are stated as at the review date for the return covering 31 December 2025, filed in 2026, and the return covering 31 December 2026, due by 31 March 2027, the information was reviewed on 6 November 2026, and all rules and figures should be rechecked before you rely on them.
Modelo 720 is the annual information return on assets and rights located abroad, introduced by Additional Provision 18 of the General Tax Law (Ley 58/2003) and set out in articles 42 bis, 42 ter and 54 bis of Royal Decree 1065/2007, with the form approved by Order HAP/72/2013. It applies to individuals and entities resident in Spain, so for expats the question is whether you are a Spanish tax resident for the calendar year. Under article 9 of the Personal Income Tax Law (Ley 35/2006) you are resident if you spend more than 183 days in Spain in the calendar year, or if your main centre or base of business or economic interests is in Spain, and you are presumed resident if your spouse, not legally separated, and dependent minor children habitually live in Spain, a presumption that can be rebutted by proving tax residence in another country. As a general starting point, Spanish domestic law has no split year, so someone who becomes resident part way through a year is generally treated as resident for the whole of it under Spanish rules, although the facts of the arrival year, treaty residence and the Beckham Law can change the practical outcome. Where you are also resident in the UK, the tie breaker in the UK and Spain double taxation convention decides which country you are treated as resident in for treaty purposes, which affects how tax is relieved but does not itself change your residence status under Spanish domestic law, and UK split year treatment under the Statutory Residence Test is a separate UK question that does not alter it either, so how this interacts with your reporting obligations should be confirmed with a qualified Spanish tax adviser. Non-resident individuals generally do not file Modelo 720. The Spanish tax agency's longstanding published guidance says people taxed under the special regime for workers posted to Spain, often called the Beckham Law, are not required to file, while family members who are Spanish tax residents in their own right are. Our guide to tax in Spain for expats explains residence and the Beckham Law in more detail.
Modelo 720 is split into three separate categories, and each is tested on its own. The first is accounts with banks and financial institutions abroad, tested on the balance at 31 December and on the average balance for the last quarter of the year, with the obligation arising if either exceeds 50,000 euros. The second is securities, rights, insurance and annuities held or managed abroad, such as shares, bonds, investment funds, life insurance policies and annuities, generally valued at 31 December, with life insurance at its surrender value and annuities at their capitalised value on that date. The third is real estate and rights over real estate abroad, valued at acquisition cost including taxes and expenses, not market value, under article 54 bis of Royal Decree 1065/2007 and the tax agency's valuation guidance. If the total in a category is 50,000 euros or less, that category does not need to be reported, but once it exceeds 50,000 euros every asset in it must be listed. According to the tax agency's guidance, joint holders each report the full value of a jointly held asset together with their percentage share, authorised signatories and people with power of disposal report accounts, effective beneficiaries report accounts and annuities, and a spouse who is the beneficial owner of property held in the other spouse's name may also need to report it. Foreign currency amounts are converted into euros at the exchange rate on 31 December. The thresholds are set in the regulations and should be rechecked each year.
The return is filed online between 1 January and 31 March of the year after the year being reported, so the return covering 31 December 2026 is due by 31 March 2027. After the first return, you only need to file again for a category if its total value has increased by more than 20,000 euros compared with the last return filed for that category, or if you have stopped holding, or stopped being an authorised person or beneficiary of, an asset that was declared or should have been declared. The tax agency's guidance says a disposal or closure of such an asset must be reported even if the category total is now below 50,000 euros, but assets opened and closed within the same year that were never reportable are not. For many expats the first Modelo 720 falls in the March after the year they became resident. Someone who moved to Spain in 2026 and is resident for that year would generally look at their position at 31 December 2026, and the last quarter average for accounts, and file by 31 March 2027 if any category exceeds 50,000 euros.
A short, complimentary call with a cross-border planning specialist can clarify your options, with no obligation.
For British expats, Modelo 720 commonly captures assets kept in the UK or elsewhere after the move. UK current and savings accounts, including cash ISAs, count as accounts abroad. Stocks and shares ISAs, general investment accounts, UK shares and investment funds count as securities, because an ISA's UK tax treatment has no effect in Spain. Life insurance policies and investment policies issued by insurers outside Spain, including unit linked policies where you carry the investment risk, are reported at their surrender value. A UK home or buy to let property is reported in the real estate category at its acquisition cost. Bank accounts and investments still held in the UAE or other countries are also included. Pensions need more care. The tax agency's guidance indicates that rights in a foreign pension plan are generally not reportable while they are only accumulated contributions, but that a pension or annuity in payment, or a plan that can be surrendered like a life policy, may need to be reported, so the treatment depends on the legal form and terms of each scheme and should be confirmed for each UK pension. These are examples of asset types that can have Spanish reporting consequences, not products offered or recommended. Cash held outside an account, gold, art and similar items are not reportable as such, although the tax agency's guidance notes that reporting can still arise where such assets underlie a reportable right, such as an annuity. Our guide to drawing your UK pension while living abroad and our guide to dividend and interest tax in Spain explain how the income itself may be taxed.
Some foreign assets do not need to appear on Modelo 720 because they are already visible to the tax agency. The tax agency's guidance gives examples including accounts at a foreign branch of a Spanish bank that the Spanish bank reports, foreign shares deposited with a Spanish entity that reports them, investment funds bought and held through a Spanish distributor, and life policies with foreign insurers operating in Spain under the freedom to provide services where their representative in Spain reports them. Assets recorded in the accounts of a Spanish company are reported by that company rather than by its shareholders. These exemptions depend on the detail of how and where the asset is held, and on the Spanish entity actually making the required report, so it is worth confirming with the institution concerned rather than assuming that an asset with a Spanish link is excluded.
Until 2022, failing to file Modelo 720 properly could lead to fixed penalties of 5,000 euros for each item of data, with a minimum of 10,000 euros, undeclared assets being taxed as unjustified gains with no time limit, and an additional penalty of 150% of the tax. In its judgment of 27 January 2022 in case C-788/19, the Court of Justice of the European Union held that these rules were disproportionate and incompatible with EU law. Law 5/2022 of 9 March 2022 removed the specific penalties, the unjustified gains rule with no time limit and the 150% penalty. Failure to file is now penalised under article 198 of the General Tax Law at 20 euros for each item or set of data, with a minimum of 300 euros and a maximum of 20,000 euros, and the tax agency's current guidance on penalties says they apply independently to each of the three reporting obligations, so where more than one category is affected, separate penalties, each with its own minimum, can apply. Under article 198.2, if a late return is filed voluntarily before any request from the tax agency, the penalty and both limits are halved, to 10 euros per item, a minimum of 150 euros and a maximum of 10,000 euros. Incomplete, inaccurate or false returns fall under article 199 of the General Tax Law. After Law 5/2022, the general four year limitation rules of the General Tax Law apply, rather than the former open ended treatment, both to penalties for the information return and, separately, to income tax assessments on any undeclared income or gains, but this does not remove exposure within those periods. These changes concern the information return. Tax due on any undeclared income or gains, together with late payment interest and the ordinary penalties for unpaid tax, can still be assessed within the normal time limits.
Since 2023, Spanish tax residents have had a separate information return, Modelo 721, for virtual currencies held abroad, introduced by Royal Decree 249/2023, which added article 42 quater to Royal Decree 1065/2007, with the form approved by Order HFP/886/2023. It covers cryptoassets held through providers located outside Spain that safeguard private keys on behalf of others, and the obligation arises where the total value at 31 December exceeds 50,000 euros. The first return covered 2023 and was filed between 1 January and 31 March 2024, and the same filing window applies each year. As with Modelo 720, a further return is needed after the first one if the total increases by more than 20,000 euros, and holdings that ceased during the year are reported as at the date they ceased. The tax agency's guidance indicates that cryptoassets in wallets where you control the private keys yourself, without a third party custodian, are not reported on Modelo 721, although they can still be relevant for income tax and wealth tax, so how they are taxed should be checked with a qualified Spanish tax adviser.
Modelo 720 is an information return only. Income and gains from assets abroad are reported and taxed through the annual income tax return, and wealth held at 31 December may also be within Spanish wealth tax (Impuesto sobre el Patrimonio) or the solidarity tax on large fortunes (Impuesto Temporal de Solidaridad de las Grandes Fortunas), which have their own thresholds, regional rules and returns and whose current status and application for the relevant year should be checked each year. Our guide to wealth tax in Spain and our guide to capital gains tax in Spain explain those taxes. Spain also receives information about financial accounts abroad from other countries under the Common Reporting Standard, which may be relevant to whether the information you report is consistent. For people planning a move, it can help to list what you hold abroad, how each asset would be classified and valued, and which returns would follow, before you become resident. Whether any change to how assets are held would be appropriate is a separate question that depends on your circumstances, the tax position in Spain and the UK, costs and investment risk. Any change to how assets are held may have tax, regulatory, cost, liquidity and suitability consequences in more than one country, and advice may conclude that no change is suitable. No product or restructuring recommendation is made in this guide. Moving to Spain also affects your estate, as our guide to inheritance tax in Spain for expats explains, and UK residence questions in the year you leave are covered in our guide to the Statutory Residence Test and split year treatment.
The first filing year is often the point at which these reporting rules first need to be considered, because Spain looks at the whole calendar year in which you become resident. Each category has its own threshold, joint assets are reported in full with your share, and a UK ISA is simply an investment abroad from Spain's point of view. It can help to list what you hold before the first March deadline. This is general information, not personal advice, and whether any action is appropriate depends on your circumstances.
Take this guide with you
Get the full guide as a PDF to read later or share, plus occasional updates when the rules covered here change.
No spam, just this guide and relevant updates. Unsubscribe any time.
Each of the three categories is tested separately. Accounts, securities and insurance, and property abroad each have their own 50,000 euro threshold.
ISA status has no effect in Spain. Cash ISAs are accounts abroad and stocks and shares ISAs are securities held abroad for Modelo 720 purposes.
The tax agency's guidance says each joint holder reports the full balance together with their percentage share, provided the category exceeds the threshold.
Disposing of or closing an asset that was declared, or should have been, must be reported in the following return even if the category total has fallen below 50,000 euros.
Since Law 5/2022 the general penalties apply: 20 euros per item, minimum 300 euros and maximum 20,000 euros, halved for voluntary late filing. Tax on undeclared income can still be assessed.
Spain has no split year in its domestic rules, so someone resident for the year they arrive may need to file by 31 March of the following year.
Expats arriving in Spain often ask whether they need to change how their investments are held. Modelo 720 is a reporting requirement rather than a tax, so the starting point is understanding how each holding is reported and taxed in Spain and in the UK. Any change involves costs, investment risk and tax consequences in both countries, and for some people no change to existing arrangements may be appropriate. This is general information, not a recommendation, and any decision needs individual advice.
Illustrative example only, not a real client. This example is simplified and fictional, applies the Spanish rules described in this guide as at November 2026 as stated assumptions, ignores currency movements and costs, and is not a guarantee of any outcome. It does not describe advice given to any client, does not represent the experience of actual clients and does not illustrate a recommended course of action. Paul and Helen are British and moved from Dubai to Valencia in March 2026, intending to stay. They kept UK savings accounts of around 40,000 euros in total, stocks and shares ISAs worth around 120,000 euros, an offshore investment policy Paul took out while in Dubai with a surrender value of around 300,000 euros, a UAE bank account they planned to close, and a flat in Bristol bought jointly for around 250,000 euros. Paul has a UK workplace pension he has not started drawing. They had not heard of Modelo 720. Offshore investment policies are not suitable for everyone and can have unfavourable Spanish tax, cost, liquidity or reporting consequences, and no view is expressed here on the suitability of Paul's policy.
In this fictional example, on these assumptions, both would be Spanish tax residents for 2026, and the reporting points that would need consideration include the following. Their securities and insurance category and their property category would each be above 50,000 euros at 31 December 2026. The Bristol flat would be reported at its acquisition cost by each of them with their percentage share. The accounts category would depend on the 31 December balance and the last quarter average, whether the UAE account was closed or still open. The ISAs and Paul's existing investment policy would be reported even though they are treated differently in the UK, Paul's undrawn pension would need checking against the tax agency's guidance on pension rights, and returns would be due by 31 March 2027. The Spanish income tax and wealth tax position of these assets are separate questions requiring their own advice from a regulated financial adviser and a qualified Spanish tax adviser. No course of action is recommended.
Illustrative outcome only: this does not assess suitability or recommend any course of action, and no tax outcome, liability or saving is guaranteed. On these assumptions, the points that would need consideration include which categories exceed the threshold for each of them, how each asset would be valued, the reporting of the UAE account when closed, and how the pension would be treated. Whether any change to how their investments are held would be appropriate is a separate question needing its own suitability assessment and tax advice, and advice may conclude that no changes are suitable. Different facts, such as becoming resident in a later year or holding assets through a Spanish institution, could produce a very different result.
Illustrative example, not a real client.
Clarity Global Wealth helps British expats living in Spain, moving there or planning their next move understand how Spanish and UK rules could apply to their savings, investments, pensions and property before they act. Clarity Global Wealth is an introducer that provides information and introductions only, does not itself give financial advice and does not advise on the suitability of any investment, pension or restructuring. We can arrange a free introduction to regulated financial planning with a separate regulated financial adviser; the introduction is an initial conversation, not advice, and places you under no obligation to proceed with advice or any product, so you can review your position with a regulated financial adviser where advice is appropriate. Any charges for advice would be explained to you before you proceed. The value of investments and pension funds can fall as well as rise, tax treatment depends on individual circumstances and can change, and advice may conclude that no changes are suitable. Clarity Global Wealth does not provide tax, legal or accounting advice, and adviser comments in this guide are general information, not personal recommendations. Preparing and filing Modelo 720, Modelo 721 and Spanish tax returns is work for qualified Spanish tax specialists, so where that is needed we coordinate with them.
Related guides: Tax in Spain for Expats, Wealth Tax in Spain for Expats, Dividend and Interest Tax in Spain for Expats, Capital Gains Tax in Spain for Expats, Inheritance Tax in Spain for Expats, Moving From the UK: The Statutory Residence Test and Drawing Your UK Pension While Living Abroad.
This guide is provided for general information only and reflects our understanding of the rules as at the date of publication. It is not personal financial, investment, pension or tax advice, and should not be relied upon as such. Rules and tax treatment can change and depend on your individual circumstances and country of residence. You should always seek regulated advice specific to your situation before taking action.
It is the annual information return Spanish tax residents use to report accounts, securities, insurance, annuities and property held outside Spain, where any one of the three categories exceeds 50,000 euros. It is filed between 1 January and 31 March of the following year.
Expats who are Spanish tax residents generally do, if they hold assets abroad above the threshold in any category. Non-resident individuals generally do not, and the tax agency's guidance says people taxed under the special regime for posted workers in article 93 of the Personal Income Tax Law, often called the Beckham Law, are not required to file, although family members who are Spanish tax resident in their own right may be.
Generally yes, if the relevant category exceeds 50,000 euros. Cash ISAs are reported as accounts and stocks and shares ISAs as securities, because ISA status has no effect in Spain.
The tax agency's guidance indicates that rights in a foreign pension plan are generally not reportable while they are only accumulated contributions, but a pension or annuity in payment, or a plan with a surrender value like a life policy, may need reporting. Each scheme should be checked.
Since Law 5/2022, failure to file is penalised at 20 euros per item or set of data, with a minimum of 300 euros and a maximum of 20,000 euros, applied separately to each category. The amounts are halved if you file late voluntarily before the tax agency contacts you.
No. After the first return, you only file again for a category if its total has increased by more than 20,000 euros since the last return, or if a declared asset has been sold, closed or otherwise ceased to be held.
Virtual currencies held through custodial providers outside Spain are reported on a separate return, Modelo 721, where the total at 31 December exceeds 50,000 euros. The tax agency's guidance indicates that self custodied wallets are not reported on it. It has the same 1 January to 31 March filing window.
Book a complimentary consultation to discuss your pensions, investments and cross-border financial planning.
A short call to understand your situation and discuss the planning options available to you.
Complimentary 30-minute consultation
Schedule a ConsultationOman income tax for expats in 2026: the 5% tax from 2028, the OMR 42,000 threshold, 183 day residence, gratuities, UK pensions and planning ahead.
Relocation & Residency TaxTax in Australia for expats in 2026: residency tests, rates up to 45%, temporary resident rules, CGT on arrival and exit, super and UK pension questions.
PensionsUK pension tax in Portugal for expats in 2026: the new UK and Portugal treaty, IRS rates on pensions, lump sums, state pension, NT codes and NHR holders.
