Do cryptocurrencies go in the 720 or somewhere else?

Lukas Hoffmann, a German engineer who works remotely from Barcelona, ended 2025 with this spread: 0.9 bitcoin on an exchange platform whose custodian entity is outside Spain, around 14,000 € in stablecoins on the same platform, another 0.6 bitcoin in a hardware wallet that he controls himself with his seed phrase, and 22,000 € in a listed bitcoin ETP bought through his Irish broker. Someone told him that "crypto goes in the 720". It does not. And each of those four positions follows a different path.

Two separate returns since 2023

Until 2022 there was no specific information return for cryptocurrencies abroad. Law 11/2021 added to the eighteenth additional provision of the Ley General Tributaria (the Spanish general tax act) a letter d) on "virtual currencies located abroad", and Royal Decree 249/2023 developed it in article 42 quater of the Reglamento General de Gestión e Inspección (the regulations on tax management and inspection). The form that gives effect to that obligation is Modelo 721, filed for the first time with the figures for 2023.

Modelo 720, the return on assets held abroad, is still governed by articles 42 bis, 42 ter and 54 bis of the same Regulations, and none of them mentions virtual currencies. So the short answer is: cryptocurrencies held by a custodian outside Spain go on the 721, not the 720.

Obligation	Form	Rule	Threshold
Accounts abroad	720 (code C)	Art. 42 bis RD 1065/2007	50,000 €
Securities, funds, insurance	720 (codes V, I, S)	Art. 42 ter	50,000 €
Real estate	720 (code B)	Art. 54 bis	50,000 €
Virtual currencies held by a custodian abroad	721	Art. 42 quater	50,000 €, its own

The 721 threshold works in the same way as those of the 720 in terms of mechanics (joint balance on 31 December valued in euros, and if it is exceeded all the currencies are reported), but it is independent: your bitcoins are not added to your bank account or your share portfolio.

The key word: custodied

Article 42 quater does not require you to report every cryptocurrency you own, only those held in custody by persons or entities that provide services safeguarding private cryptographic keys on behalf of third parties. And it treats them as located abroad when that custodian is not obliged to file in Spain the balance return that the Spanish income tax act imposes on resident custodians (the one given effect in Modelo 172).

Two successive filters follow from that:

1. Is there a third party holding your keys? If the wallet is yours and so are the private keys, there is no custodian. Those coins do not go into the 721.
2. Is that custodian outside the Spanish reporting system? If the platform is an entity resident in Spain or a permanent establishment here, it already reports; your coins are not treated as located abroad.

The Agencia Tributaria, the Spanish tax agency, sums this up itself in its frequently asked questions on Modelo 721: coins in wallets where the user keeps control of the keys do not count towards the balance for that return.

Lukas's four positions, one by one

Position	Where is it reported?	Reason
0.9 BTC on a platform with a foreign custodian	Modelo 721	Virtual currency held by a third party outside Spain
14,000 € in stablecoins on the same platform	Modelo 721	They are still virtual currencies held in custody
0.6 BTC in his own wallet	Neither 720 nor 721	There is no custodian
Bitcoin ETP with an Irish broker	Modelo 720, securities block	It is a traded security, not a virtual currency

Now the 721 threshold calculation. Let us assume a price of 90,000 € per bitcoin on 31 December (a figure made up for the example):

1. bitcoin in custody: 0.9 × 90,000 € = 81,000 €;
2. stablecoins: 14,000 €;
3. joint balance for the purposes of the 721: 95,000 €, above 50,000 €;
4. his own wallet (0.6 × 90,000 € = 54,000 €) is not added, even though on its own it would also be above the threshold.

Lukas files the 721 for 95,000 €. The ETP, on the other hand, is added to the rest of his securities block for the 720: if together with his shares and funds at the Irish broker it exceeds 50,000 €, he declares it there; if not, he does not.

Not being reported does not mean it does not exist

Lukas's own wallet is the point that causes most confusion. It does not appear in any information return, but:

• if he sells or swaps those bitcoins, the gain or loss is declared in his IRPF (Spanish personal income tax) return;
• if he is liable to the Impuesto sobre el Patrimonio (Spanish wealth tax), those coins form part of his net worth just like the ones in custody;
• and if Hacienda, as the Spanish tax office is commonly known, ever asks him where the money for a purchase came from, the traceability of that wallet will be his only defence.

That is why we advise documenting self-custody even when it does not have to be reported: public addresses, the history of transfers from the platforms and the value at year end. It is the same evidence that will later be used to work out the acquisition cost.

If your positions are spread across platforms, your own wallets and listed products, you can list them in the Modelo 720 form, saying where each one is held, and we will tell you which of the two returns each piece belongs in.

Products that look like crypto but are not

The test is the legal nature of the asset, not its underlying:

• ETFs, ETPs or ETNs on cryptocurrencies bought through a foreign broker: they are securities. They go in the securities block or the collective investment schemes block of the 720, depending on their form.
• Shares in mining companies or crypto platforms: they are shares. Securities block of the 720.
• A balance in euros or dollars inside a foreign exchange: this is not a virtual currency. Whether that balance falls within the accounts block of the 720 depends on which entity holds it and on what terms; it is a point to review case by case with the platform's documentation.
• Tokens representing equity or debt: they need analysing; depending on how they are structured they may be closer to a security than to a virtual currency.

The calendar is the same

The 721 is filed between 1 January and 31 March of the following year, exactly like the 720, and it also has the rule of not repeating unless the joint balance grows by more than 20,000 € over the last return, or you stop holding coins you have already declared. People with both kinds of asset usually prepare them together, but they are two independent filings with independent thresholds.

To see how it is completed in practice, with the valuations and the custodian's details, read on in how Modelo 721 is filled in or in the guide to Modelo 721 for cryptocurrencies.

At Salama Tax we prepare the 720 and the 721 together for residents with assets outside Spain; that page explains the scope of the work and the documents we usually need.