Tomasz Nowak, a Polish programmer who has lived in Seville since 2021, invests through a trading app whose custodian entity is in Germany. On 31 December 2025 he held there shares in US companies worth $61,000, three Ireland-domiciled ETFs worth 38,000 €, shares in a Spanish bank worth 7,000 €, 9,000 € in uninvested cash and, in the crypto section of the same app, 0.4 bitcoin. On his screen it all appears as a single "portfolio". For Hacienda, as the Spanish tax office is commonly known, it is not: some pieces go on the 720, one goes on the 721, and some require a look at the small print.
Securities versus virtual currencies
The first distinction is legal, not commercial. Modelo 720, the Spanish return on assets held abroad, covers in its securities block (article 42 ter of the Reglamento General de Gestión e Inspección, Royal Decree 1065/2007) shares and holdings in entities, securities representing the transfer of capital to third parties, and units in collective investment schemes located abroad. Virtual currencies are not there: they have their own obligation in article 42 quater and their own form, Modelo 721.
The fact that the same broker offers both in the same app does not merge them. The crypto side is usually provided by another group entity or by a third party that holds the keys, and it is that entity which determines whether the coins are "abroad".
| Tomasz's position | Nature | Return | Code |
|---|---|---|---|
| US shares | Equity securities | 720 | V |
| Irish ETFs | Collective investment schemes | 720 | I |
| Shares in a Spanish bank | Securities deposited abroad | 720 | V |
| Cash in the app | Depends on who holds it and how | To be reviewed | C? |
| 0.4 bitcoin | Virtual currency held in custody | 721, if total crypto exceeds 50,000 € | — |
The code for ETFs has been set by the Agencia Tributaria, the Spanish tax agency, itself in its frequently asked questions: they are declared under code I, as units in collective investment schemes, and not as shares.
Why the Spanish shares go in too
It seems counter-intuitive to declare a share in a Spanish bank as an "asset abroad". But the eighteenth additional provision of the Ley General Tributaria (the Spanish general tax act) refers to securities deposited or located abroad, and Tomasz's are deposited in Germany. No Spanish institution reports them to the Agency.
The reverse case is resolved by the Agency in its frequently asked questions: foreign shares deposited with a Spanish institution that already reports on them are not declared on the 720. What matters is where the deposit is and who reports, not the nationality of the issuer.
The calculation for the block
Everything that is a security or a collective investment scheme is added up in the same block. With an assumed exchange rate of 1.05 dollars to the euro on 31 December:
- US shares: $61,000 / 1.05 = 58,095 €;
- Irish ETFs: 38,000 €;
- Spanish shares deposited in Germany: 7,000 €;
- total for the securities block: 103,095 €, above the threshold.
Tomasz declares all three items. And not as a single line: each security, with its ISIN code, goes in a record of its own. The Agency expressly requires this when a custody account groups individual items with different codes.
As for the value, for shares listed on foreign markets the Agency accepts either the price on 31 December or the rules in articles 15 and 16 of the Spanish wealth tax act. For ETFs, as collective investment schemes, the net asset value on 31 December is reported. Choosing one criterion and sticking to it makes it easier to compare years for the 20,000 € rule.
The omnibus account
Many brokers do not register shares in each client's name with the central depository, but in a global account in the name of the broker or its sub-custodian, and keep in their own books which part belongs to each client. This is the omnibus account.
For the 720 that does not change who the holder is: Tomasz is still the holder of his shares, even though they are not in his name in the issuer's register. What changes is how two confusing fields are filled in:
| Field | What goes in it | Tomasz's example |
|---|---|---|
| Country where the securities are deposited or managed | That of the depositary institution | Germany, for all of them |
| Country of domicile of the issuer | That of the company or the fund | USA for his shares, Ireland for the ETFs, Spain for the bank |
The Agency explains this with an equivalent example: shares in a French company deposited with a broker based in Germany have Germany in the first field and France in the second.
The app screen shows real-time market values and groups positions together. For the 720 you need the annual tax report or the statement of positions on 31 December, with ISIN, number of securities and depositary institution. If the broker does not provide one, it is wise to download the statement on 31 December itself or on the first business day afterwards; rebuilding it months later is much harder.
If your portfolio mixes shares, funds, cash and cryptocurrencies in one app, in the Modelo 720 form you can describe what you hold in each section and who is named as custodian in your contract; with that we separate what goes on each form.
Uninvested cash
The 9,000 € in cash is the point that requires reading the contract. The accounts block of the 720 refers to accounts with institutions engaged in banking or lending business. Depending on how the broker is organised, the cash may be in an account in the client's name at a bank, in a client money account in the broker's name, or in money market funds. Each situation reads differently, and we do not give a general answer. In Tomasz's case the amount is small, but in portfolios where cash exceeds 50,000 € the classification decides whether there is a second block to declare.
What is not declared
- Share options: the Agency's answer is that there is no obligation to report them. The shares received on exercising them do go in, from the moment they are held. The case of employees with company plans is dealt with in the guide on equity and Modelo 720.
- Loans or credit not represented by securities: the transfer of capital to third parties is only reported when it is represented by securities.
And the bitcoin
The 0.4 bitcoin goes on the 721 only if the joint balance of virtual currencies held in custody abroad exceeds 50,000 €. If Tomasz has no other cryptocurrencies, 0.4 bitcoin does not usually reach that figure, but the price decides and it has to be checked every 31 December. How that form works in full is explained in how Modelo 721 is filled in.
Portfolios with foreign brokers are one of the most common situations at Salama Tax; that page describes how we prepare the 720 from the broker's report and how we reconcile it with the gains declared for income tax (IRPF).