The question arrives every February: "I filed it last year, do I have to do it again?" The answer does not depend on what you own today, but on the comparison between what you own and what you last declared. Without that earlier snapshot there is no way to answer, and that is why this formality gets complicated when you change adviser.
The rule, in three cases
After you have filed Modelo 720, the Spanish information return on assets abroad, for a given block, the obligation to file for that block returns when:
- The combined value of the block rises by more than €20,000 compared with the value shown on the last return filed.
- One of the assets declared has been extinguished or closed: an account that is closed, a property that is sold, an insurance policy that is surrendered.
- Or, in a block that was never declared, the €50,000 threshold is exceeded for the first time.
If you declared in 2022 and have not filed since, this year's comparison is made against the 2022 values, not the 2025 ones. The €20,000 is not annual: it is cumulative since the last snapshot. It is the detail we have had to correct most often when reviewing the history of a new client.
A five-year example
A taxpayer with a single account abroad and no other assets:
| Tax year | Value of the accounts block | Reference | Files? |
|---|---|---|---|
| 2022 | €62,000 | First time above €50,000 | Yes |
| 2023 | €71,000 | +€9,000 over 2022 | No |
| 2024 | €78,000 | +€16,000 over 2022 | No |
| 2025 | €84,000 | +€22,000 over 2022 | Yes |
| 2026 | €90,000 | +€6,000 over 2025 | No |
Look at 2024: although the account had risen by €16,000, and the following year rose by only €6,000 more, it is in 2025 that the limit is crossed, because the measure is against 2022. And look at 2026: once the 2025 return has been filed, the counter resets and that tax year becomes the reference.
Closures are declared even if the block goes down
This case is the one that causes the most silent breaches, because nobody links "selling" with "declaring". If you close the account you declared, sell the property you declared or surrender the insurance policy you declared, you have to file Modelo 720 for that tax year reporting the extinction, even though your wealth abroad has fallen and even if you no longer exceed any threshold.
The logic of the form is one of tracking: the tax authority needs to know that the asset is no longer there, and failing to close that record leaves a declared asset that never appears again. A few years later, that is exactly the kind of inconsistency that sets off a tax audit.
Changes that do not look like changes, but are
- Changing bank. Closing the account at one institution and opening another leaves one closure and one addition, even if the total balance is identical.
- The exchange rate. An account in dollars or pounds can rise by more than €20,000 in euro terms without its holder paying in a single cent. The obligation is measured in euros.
- Increases in value. A good year on the stock market can trigger the securities block on its own.
- An inheritance. Receiving an asset abroad adds a new asset to the corresponding block.
Conversely, some things trigger nothing: a fall in value, moving money between accounts already declared, or the bank changing your branch. Whatever does not change the block's total and does not extinguish a declared asset creates no obligation.
Two blocks, two counters
When there is more than one block, each keeps its own count and they never mix. An example with two:
| Tax year | Accounts | Securities | What is filed |
|---|---|---|---|
| 2023 | €58,000 | €41,000 | Only the accounts block, which is the one above the threshold |
| 2024 | €63,000 | €54,000 | The securities block, which crosses €50,000 for the first time |
| 2025 | €66,000 | €59,000 | Nothing: neither rises by more than €20,000 over its own reference |
| 2026 | €81,000 | €61,000 | The accounts block, which exceeds what was declared in 2023 by more than €20,000 |
Note 2024: the accounts block rose by €5,000 and did not have to be declared, but the securities block came in for the first time. One return is filed including the block that is obliged; what should not be done is to take the chance to declare again what is not due, because that moves that block's reference point and changes the calculation for the following years.
The closure return
When a declared asset is extinguished, the record does not simply disappear: it is filed with the date of closure or extinction and the value corresponding to that moment, with the origin key showing that it is a removal. That is how the record is closed, and it is the reason a sale or an account closure obliges you to file even though your wealth has gone down.
One detail that is forgotten: if in the same tax year one asset is closed and another is added, both movements go on the same return, each with its own key. They are not two returns, and they do not offset each other.
Why the history has to be kept
Without knowing what you declared, you cannot decide whether you have to declare. It is as simple as that. And the history gets lost with astonishing ease: people change adviser, change computer, forget the password to the email account where the receipt was.
It can be recovered: returns filed can be consulted on the electronic office of the Agencia Tributaria, the Spanish tax authority, with a digital certificate or Cl@ve. What is worth doing is downloading the receipt with its secure verification code and the detail of the assets declared, and keeping them in the same place as your property deeds. When we open a new file, this is the first thing we ask for, before the balances for the current year.
The obligation is assessed per person, not per family
The increase counter is individual. In a married couple with a joint account declared by both, if the balance rises by €30,000, both are obliged again, because the threshold is measured on the total value of the asset and not on each spouse's half. And the other way round: an asset belonging to only one of the spouses moves his or her block and not the other's. It is common for one return to be due in a household in a given year rather than two, and that is not a mistake.
The same goes for the capacity in which each asset is held. Someone who goes from being an authorised person on an account to its holder (because the holder dies and the estate is allocated) is not facing a simple change of label: he or she has added an asset to his or her block, at its full value, and that may trigger the obligation even if the account has been declared for years by somebody else.
A year without filing is not a blank year
Even when there is no obligation, it is worth doing the calculation and keeping it on record: the values of each block, the exchange rate used and the comparison with the last return. It costs little, and it answers the only question that matters if a letter ever arrives: why nothing was filed for that tax year. Answering "because I was below the limit" is an assertion; answering with the institutions' certificates and the calculation done is evidence.
What we do every January with a client in this line
We pull out the last return filed for each block, ask the institutions for certificates of the values at 31 December, apply the year-end exchange rate and compare. The answer fits on one sheet: block by block, previous value, current value, difference and conclusion. That sheet is always filed away, whether a return is made or not, and over the years it becomes the history that stops February's question from being a question at all.
And if you find out that you should have filed
You can file late, and doing it on your own initiative before any request from the tax authority is not the same as doing it afterwards: the regime in force since Ley 5/2022 draws a clear line between the two situations, as we explain in the penalty regime today. What counts as a prior request, and therefore closes the door on the voluntary route, is in what counts as a prior request.
If several tax years are outstanding, the order in which they are filed is not a matter of indifference, and it deserves some analysis before you start uploading files: the order for regularising several years.
Our method with your assets abroad
For clients in this line we keep the snapshot of each tax year: what was declared, at what values and at what exchange rate. Every January the comparison is done in an afternoon, and the answer is a reasoned yes or no, not an impression. If you arrive with scattered years and no papers, the first job is to rebuild the history; it is work, but it is work that only has to be done once. The Modelo 720 form asks exactly about that: what you filed, when, and what has changed since.