Who this applies to, and who it does not
Form 720 is an obligation of people who are tax resident in Spain. If you are resident here, Spain taxes your worldwide income and wants an annual inventory of what you hold elsewhere. If you are a non-resident who simply owns a flat on the coast, this page is not yours: your obligations are form 210 on the property and little else.
Residence is not about nationality or about having a residence card. In broad terms you are resident if you spend more than 183 days of the calendar year in Spain, or if your main centre of economic interests is here. A British retiree who moved to Alicante three years ago is resident; a Spaniard who has lived in Zurich for a decade is not. The passport says nothing either way.
Three blocks, and a threshold on each of them
The return covers assets and rights located outside Spain, grouped into three blocks that are independent of one another. Each block has its own threshold of 50,000 €, and you only report a block if that block passes it.
| Key | Block | What goes in it |
|---|---|---|
| C | Accounts | Current accounts, savings accounts and deposits at financial institutions |
| V · I · S | Securities, funds and insurance | Shares and holdings (V), investment funds (I), life assurance and lifetime or temporary annuities (S) |
| B | Immovable property | Property and rights over property |
Two joint holders of an account with 60,000 € in it both file, each stating their percentage. Nobody holds 30,000 € for these purposes: the account is above the threshold and both holders report it. This is the single most repeated error, and the easiest one to avoid.
The year after: when you file again, and when you do not
Once you have filed a block in any year, you only come back to it in a later year if one of two things has happened:
- The combined value of that block has risen by more than 20,000 € compared with the last figure you reported for it, or
- an asset you had previously reported has been sold, closed or otherwise extinguished, which has to be reported whatever the amounts are.
Which is why the history matters more than the current balance. Without knowing exactly what was declared last time, and for which block, nobody can decide whether there is anything to declare this time. People who lose that record end up filing every year out of caution, or not filing at all without realising they should have.
The deadline, and what the penalty regime looks like now
From 1 January to 31 March of the following year, in respect of the previous calendar year. Electronic filing only, which in practice means a digital certificate or a formal authorisation in favour of whoever files for you.
The special penalty regime that made this return notorious — fixed fines per data item, and an unjustified capital gain with no time limit — was struck down by the judgment of the Court of Justice of the European Union of 27 January 2022, and Spain amended the rules through Law 5/2022. What applies today is the general regime of the General Tax Act. That is still serious, but it is proportionate, and the old rule under which an undeclared foreign asset could be taxed regardless of how many years had passed is gone.
Coming forward yourself is still far better than waiting, and the arithmetic has not changed: a surcharge if you file first, a penalty if they write to you first. With automatic exchange of information between tax administrations, the balance on a foreign account is already sitting in a file in Madrid. Waiting stopped being a strategy some time ago.
How each asset is valued
Half the errors on this return are valuation errors, because there is no single rule. Each category has its own:
| Asset | Value to report |
|---|---|
| Bank accounts | Balance at 31 December and average balance over the last quarter |
| Listed securities | Market value on 31 December, or the average trading value over the fourth quarter (the Agencia Tributaria accepts either) |
| Investment funds | Net asset value at 31 December |
| Life assurance | Surrender value at 31 December |
| Property | Acquisition cost, not market value |
Accounts carry both figures, and the 50,000 € threshold is tested against the higher of the two. The property rule surprises almost everybody: a house bought twenty years ago for 80,000 € is reported at 80,000 €, even if it would sell today for three times that. This is an inventory of what you paid, not a statement of what you are worth.
Amounts in another currency are converted at the official exchange rate at 31 December. Each asset then carries its key, its sub-key, the country it sits in and your percentage of ownership: the return is a set of fields per asset, not a set of totals.
Your case, in two minutes
Your assets abroad: your map of obligations
The form for this service asks only what matters here. At the end you have your map of obligations, the deadlines running against you and a fixed price.
Crypto has its own return: form 721
Virtual currencies held abroad are reported on form 721, which has its own 50,000 € threshold and runs to the same deadline. If your holdings sit on a foreign exchange, that is your return, not the 720. Coins held in a wallet whose keys you control are a separate question, and one worth asking before the deadline rather than after it.
What this return does not do
Filing the 720 does not tax anything and does not discharge anything else. The income those assets produce — interest, dividends, rent, capital gains — still belongs in your Spanish income tax return, and the same assets may also have to be reported for wealth tax purposes on form 714, which is a different return with different thresholds and different valuation rules. People who file the 720 and assume the rest is covered are the ones who receive a letter from the tax office two years later.
Our method with your assets abroad
We build your inventory of foreign assets as a table, one row per asset and per holder. From there the system does three things: it totals each block, it compares those totals against the last figures you reported, and it tells you asset by asset whether you are obliged to file and on what ground. Only once that has been reviewed and confirmed is the file generated for submission.
We also keep the history of what was reported in each year, which is exactly what is needed to make the decision the following year. For clients on one of our recurring lines, the 720 is part of the monthly fee rather than a separate bill. If all you want is a one-off review of whether you should have been filing at all, say so and we will price that on its own.
Questions we are asked about your assets abroad
Is anything paid with the 720? No. It is purely informative. The cost is in not filing it, or filing it wrongly.
I have an account with 30,000 € and a fund with 40,000 €. Do I file? No. They are different blocks and neither block reaches 50,000 €. If both amounts sat in the same block, you would.
I am not resident in Spain. Does it affect me? No. The 720 is for Spanish tax residents only.
I am on the Beckham regime. Do I file it? No. Someone taxed under article 93 is not required to file the 720 while the regime lasts, and the Agencia Tributaria says so in its own FAQs on the form, because that taxpayer is not taxed on worldwide income. Two caveats worth having in writing: the exemption belongs to the person in the regime, so a spouse or children who have not opted in may still have to file; and in the year the regime ends, the 720 comes back with everything you hold abroad on 31 December.
My bank abroad already reports to Spain. Why file? Because the obligation is yours, not the bank's, and the information the bank sends is not the same information the return asks for. The exchange of data is the reason omissions get noticed, not a substitute for the filing.