Nadia Haddad has dual Lebanese and French nationality and has lived in Marbella since 2019. Her wealth, about 2,600,000 € in assets, is spread between her home, a let flat in Málaga, an account and a portfolio in Paris and a deposit in Beirut. Nobody ever told her about Modelo 714 or Modelo 720. In September 2026, while preparing the sale of the Málaga flat, her notary asked whether she was up to date with Hacienda, the Spanish tax office, and she wrote to us with a direct question: how much is this going to cost me? The answer depends on which years are still open, on whether there was tax to pay in those years or not, and on the order in which things are done.
Which years can be claimed
Article 66 of the Ley General Tributaria, the Spanish general tax law, sets the limitation period for the authorities' right to assess tax at four years. Article 67 starts that period on the day after the filing period for the return ends. Any action by the authorities with the taxpayer's formal knowledge, or any action by the taxpayer aimed at paying or regularising, interrupts the count.
For Modelo 714, the filing period is set each year by ministerial order. For the example, let us assume it ended at the end of June each year:
| Tax year | End of filing period (assumed) | Time-barred (without interruptions) | Open in October 2026? |
|---|---|---|---|
| 2021 | End of June 2022 | End of June 2026 | No |
| 2022 | End of June 2023 | End of June 2027 | Yes |
| 2023 | End of June 2024 | End of June 2028 | Yes |
| 2024 | End of June 2025 | End of June 2029 | Yes |
| 2025 | End of June 2026 | End of June 2030 | Yes |
The 2019 and 2020 tax years are also time-barred. The guide on the four-year limitation period explains interruptions in more detail, and how many years back they can claim sums up the count.
Two kinds of year: with tax and without tax
Nadia lives in a region whose rules, depending on the tax year, left her bill at zero or made her pay something. In every year she exceeded 2,000,000 € in assets, so in every year she was obliged to file. But the cost of catching up is different in each case:
Years with a zero bill. No payment is outstanding, so there is no surcharge or interest. What there is, is the offence in article 198 of the Ley General Tributaria of failing to file a return without financial loss to the Treasury: a fixed fine of 200 €, which is halved if the return is filed late without a prior request.
Years with tax to pay. Article 27 applies: filing late without a prior request means a surcharge of 1 % plus a further 1 % for each full month of delay, and after 12 months, a surcharge of 15 % plus late-payment interest from the day after the end of those 12 months. The surcharge rules out penalties.
Nadia's figures
Let us suppose that, under her region's rules, her tax bills were these, and that she files everything on 15 October 2026:
- 2022: tax 0 €. The reduced article 198 fine: 100 €, if the authorities impose it.
- 2023: tax 0 €. Another 100 €, on the same terms.
- 2024: tax 3,200 €. Filing period ended at the end of June 2025: more than 12 months have passed. Surcharge of 15 %: 480 €. Plus late-payment interest from the day after those 12 months are completed until 15 October 2026.
- 2025: tax 3,600 €. Filing period ended at the end of June 2026: three full months of delay. Surcharge of 1 % + 3 % = 4 %: 144 €.
- Approximate total, without interest: 3,200 + 3,600 in tax, 624 € in surcharges and up to 200 € in fines.
The details of the surcharge calculation are in the guide on how to calculate the article 27 surcharge and in how much the surcharge for filing late is.
These figures only hold if you file before any action by the authorities aimed at regularising that tax. Once a request has been received, there is no longer a surcharge but an assessment with interest and, where applicable, a penalty, which can be much higher. A letter from the Agencia Tributaria is not always a request, but it is better not to wait to find out; we explain it in the guide on what counts as a prior request.
If Modelo 720 is missing too: the order matters
Nadia did not file Modelo 720, the return declaring assets held abroad, for her account in Paris, her portfolio and her deposit in Beirut either. And she may not have declared in IRPF (Spanish personal income tax) the interest and dividends from those accounts. When several pieces are missing, the order in which they are regularised changes the result. The one we propose is this:
- Inventory at each 31 December. A single table with all the assets, balances and values for each open year. Modelo 714 and Modelo 720 both come from it, and it avoids inconsistencies between the two, which is the first thing the authorities would cross-check.
- IRPF for the open years. If there is undeclared foreign income, it is regularised first with supplementary returns. Wealth tax depends on it: the joint cap with income tax is calculated on the IRPF bases and tax.
- Modelo 720. It is filed late for the years in which the obligation existed. After the judgment of the Court of Justice of the European Union, its special penalty regime disappeared and the general rules for information returns now apply; this is explained in the guide on Modelo 720 penalties after the CJEU judgment.
- Modelo 714 for each open year. With the IRPF bases already corrected and the values from the inventory.
The guide on the order for regularising several tax years and the answer on regularising several years at once develop the logic. The relationship between the two returns is in how Modelo 720 relates to wealth tax.
What is best avoided
- Filing only the last year. Article 3 of Law 19/1991 presumes that the assets you had at the previous accrual date are still yours, unless proved otherwise. Filing 2025 with 2,600,000 € and nothing before it leaves the earlier years exposed.
- Filing Modelo 714 with values that do not match Modelo 720. The two use different valuation rules, but the assets must be the same.
- Waiting for the oldest year to become time-barred. The count may have been interrupted without your knowing, and meanwhile the following years build up surcharges.
How long it takes and what happens afterwards
Preparing five tax years with a full inventory takes a few weeks if the bank paperwork is available; with banks outside the European Union it can take longer. After filing, the authorities assess the surcharges and interest and, for the years with a zero bill, may open proceedings for the fine. They may also review the substance of any tax year that is not time-barred. Filing voluntarily greatly reduces the cost and the risk, but there is no way to guarantee that there will be no later check.
If you are in a similar situation, the first thing is to find out whether your wealth really exceeded the thresholds each year; we explain it in from what amount you have to file. To get started, you can send us whatever you have through the wealth tax form. Anything concerning the taxation of the accounts in France or Lebanon under their own laws must be confirmed by the client's adviser there.
Regularising past tax years, together with the threshold, the valuation rules and the table by region, is part of the Salama Tax page on the wealth tax.