The Modelo 720 is Spain’s mandatory informational declaration of foreign assets held by Spanish tax residents. It operates across three independently assessed categories: foreign bank accounts, foreign securities and investment rights, and foreign real estate. Each category carries a EUR 50,000 threshold — assessed separately, not in aggregate. If the value of assets within any single category exceeds EUR 50,000 on 31 December, the obligation to file arises for that category. The annual deadline is 31 March of the following year. The filing obligation is set by Ley 7/2012, as reformed by Ley 5/2022 following the ECJ Case C-788/19 ruling in 2022. The Modelo 720 is a purely informational form — it does not generate a tax bill directly, though undeclared foreign assets can carry significant consequences.
Modelo 720 has three separate EUR 50,000 thresholds — one per category. A foreign bank account worth EUR 60,000 triggers the obligation for Category 1 even if you have no foreign investments or property.
Source: Ley 7/2012, de 29 de octubre
What Is the Modelo 720 and Who Must File?
The Modelo 720 is an informational declaration — not a tax form in the conventional sense. Filing it does not itself produce a tax liability. Its purpose is to give the Spanish Tax Agency (AEAT) visibility over assets that Spanish tax residents hold outside Spain.
The three-category structure
Spain divides foreign assets into three categories, each assessed independently:
Category 1 covers accounts held at foreign banks or financial institutions — current accounts, savings accounts, and term deposits.
Category 2 covers foreign securities and rights: shares listed on foreign stock exchanges, unlisted company shares, pension rights accrued in foreign occupational or private schemes, life insurance policies with foreign insurers, annuities, and investment funds (such as UCITs, ETFs, or mutual funds) held on foreign platforms.
Category 3 covers real estate located outside Spain, along with rights over real estate such as usufruct or long-term lease arrangements.
Each category is assessed against EUR 50,000 on its own. A resident with EUR 30,000 in a foreign bank account and EUR 80,000 of property in France files only for Category 3. The account does not breach the threshold; the property does.
Who is obligated to file
Spanish tax residents who meet the criteria of Article 9 of Ley 35/2006 (LIRPF) are subject to the Modelo 720 obligation. Non-residents paying Spain’s non-resident income tax (IRNR) are not subject to the declaration. Residents under the Beckham Law special regime are also exempt during the regime period — see the dedicated section below.
For the full rules on how Spain determines tax residency — including the 183-day rule, the economic interests test, and the family presence presumption — see the Spain Tax Residency guide.
What Do the Three Categories Cover?
Understanding exactly which assets fall into each category prevents both over-reporting and under-reporting.
Category 1 — Foreign bank and financial accounts
Category 1 covers all accounts held with banks or financial institutions located outside Spain. This includes current accounts, savings accounts, and time deposits. The threshold is assessed using the higher of two figures: the balance on 31 December of the tax year, or the highest balance recorded at any point during the year. If either figure exceeds EUR 50,000, the category must be declared.
A note on jointly held accounts: the applicable balance is typically the full account balance rather than each holder’s proportional share, though the precise treatment depends on the account structure. If you hold foreign accounts jointly, confirm the applicable methodology with your asesor fiscal before filing.
Category 2 — Foreign securities, insurance, and pension rights
Category 2 is Spain’s broadest Modelo 720 category: it covers shares and participations in listed and unlisted foreign companies, investment funds and ETFs held on non-Spanish platforms, occupational and private pension rights accrued outside Spain, life insurance policies with foreign insurers, and annuities under foreign schemes. Assets in this category are valued at market value on 31 December of the tax year. A pension pot of EUR 60,000 in a UK workplace pension scheme, for example, triggers the Category 2 obligation.
Platforms such as DEGIRO, Vanguard US, or Fidelity UK are common Category 2 triggers for expats who maintained investment accounts before relocating to Spain.
Category 3 — Foreign real estate and rights
Category 3 covers property located outside Spain — whether residential, commercial, or land. It also captures rights over foreign property, including usufruct (the right to use and enjoy property), long-term leases, and similar arrangements.
Unlike Categories 1 and 2, the threshold for Category 3 is assessed against acquisition cost, not current market value. A property bought for EUR 45,000 in 2010 that is now worth EUR 80,000 does not trigger the Category 3 obligation — the EUR 45,000 acquisition cost is below the threshold.
| Category | What It Covers | Threshold | Valuation Basis |
|---|---|---|---|
| 1 — Accounts | Foreign bank and financial accounts | EUR 50,000 | Highest balance during year or 31 Dec balance |
| 2 — Securities and rights | Shares, funds, pensions, life insurance | EUR 50,000 | Market value on 31 Dec |
| 3 — Real estate | Foreign property and rights over property | EUR 50,000 | Acquisition cost |
You only file for the categories that breach the EUR 50,000 threshold. If your foreign bank balance is EUR 30,000 and your foreign property cost EUR 80,000, you file Category 3 only — Category 1 falls below the limit.
Source: Ley 7/2012, de 29 de octubre
Deadlines, Re-filing Rules, and the 2022 Penalty Reform
Modelo 720 compliance has two components: the initial filing when you first breach a threshold, and ongoing obligations in subsequent years.
The 31 March deadline
The Modelo 720 must be filed by 31 March of the year following the tax year in which you first breach a threshold. If you became a Spanish tax resident in 2025 and your foreign bank account exceeded EUR 50,000 during 2025, your first Modelo 720 is due by 31 March 2026.
There is no automatic extension. Filing after 31 March constitutes a late filing and attracts penalties, even under the reformed regime introduced by Ley 5/2022.
When you must re-file
After the initial declaration, re-filing is not automatic every year. You are only required to re-file for a category that was previously declared in two situations:
First, if the value within that category changes — upward or downward — by more than EUR 20,000 compared to the last declared figure. Second, if you acquire new assets that fall within a category, or dispose of assets that were previously declared.
If your declared assets remain broadly stable with no movement exceeding EUR 20,000 and no new acquisitions or disposals, no re-filing is required for that year.
What the ECJ ruling changed — and what it did not
In January 2022, the European Court of Justice ruled in Case C-788/19 that Spain’s original Modelo 720 penalty framework was disproportionate and contrary to EU law on freedom of movement of capital. The original regime imposed automatic surcharges of 150% of the undeclared asset value — penalties entirely out of proportion to the general Spanish tax penalty framework.
Ley 5/2022 (de 22 de marzo) responded by reforming the penalty regime. Post-reform, non-compliance penalties are proportional and aligned with the general penalty scale that applies to other tax infractions in Spain.
Critically: the ECJ ruling addressed the penalties, not the filing obligation. The Modelo 720 itself — the requirement to declare foreign assets above EUR 50,000 per category — was not challenged and remains fully in force. Taxpayers who were subject to the disproportionate old-regime penalties may have grounds for a state liability claim, but this requires specialist legal advice.
Ley 5/2022 reformed Modelo 720 penalties after the ECJ ruled them disproportionate — but the filing obligation itself was not affected. You still must file if you breach any EUR 50,000 threshold.
Source: Ley 5/2022, de 22 de marzo; ECJ Case C-788/19
If you hold crypto assets on foreign exchanges, a separate declaration applies. The Modelo 721 — introduced for the 2023 tax year — covers foreign-held crypto assets and operates on the same EUR 50,000 threshold. For the full rules on crypto tax reporting in Spain, see the Spain crypto tax guide.
Modelo 720 and the Beckham Law — A Key Exception
Expats on the Beckham Law special tax regime (Article 93 of Ley 35/2006, as expanded by Ley 28/2022) are subject to IRNR rules — Spain’s non-resident income tax framework — rather than standard IRPF rules. This means they are treated as non-residents for income tax purposes during the regime period.
Because the Modelo 720 obligation rests on being an IRPF taxpayer under obligación personal (worldwide tax obligation), Beckham Law holders sit outside its scope. While on Beckham, there is no Modelo 720 obligation for foreign assets — regardless of how much those assets are worth.
This exception carries an important caveat: it is temporary. Once the Beckham period ends — after the year of arrival plus five subsequent tax years — the taxpayer transitions to standard IRPF. From that point, the Modelo 720 obligation applies from the first full year of standard residency in which a threshold is breached.
For expats holding substantial foreign assets and approaching the end of their Beckham period, understanding when the Modelo 720 obligation begins is part of a well-structured transition plan.
Beckham Law holders are taxed as non-residents — which means no Modelo 720 obligation during the regime. That changes the moment you exit Beckham and enter standard IRPF.
— ApexTax — Spain Tax Strategy
For those planning a Beckham-to-standard-IRPF transition, see the full Beckham Law guide for the rules on the regime period and what happens at exit.
How ApexTax Helps You Navigate the Modelo 720
The Modelo 720 sits at the intersection of tax residency planning and foreign asset management — and the consequences of missed filings are real even under the reformed penalty framework.
ApexTax maps your foreign asset profile against the three category thresholds, identifies the tax years in which the filing obligation arose or will arise, and flags re-filing triggers in subsequent years. Where a Beckham-to-standard-IRPF transition is approaching, we integrate the Modelo 720 timeline into your broader tax transition plan.
Technical preparation and formal submission of the Modelo 720 is carried out by independent qualified asesores fiscales coordinated by ApexTax. We do not file the declaration ourselves, nor do we represent clients before AEAT. Our role is strategic — assessing your position, designing the right approach, and coordinating the right specialist for execution.
If you are a Beckham Law holder approaching the end of your regime period, or a newly arrived resident uncertain whether your foreign assets trigger the filing obligation, a structured assessment is the right starting point.