Ingrid Lindqvist is Swedish, has lived in Fuengirola since 2021 and on 31 December 2025 held the following outside Spain: 38,000 € in an account with a Stockholm bank, a Swedish investment fund worth 29,000 €, a savings insurance policy with a surrender value of 24,000 € and a small flat in Uppsala that she bought in 2004 for the equivalent of 46,000 €. Added together, that is 137,000 €. Her neighbour told her that "once you go over 50,000 you have to do the 720". Ingrid assumed she had to report everything. In fact she only has to report part of it, and that part is not the one she expected.
The 50,000 € is not added up across blocks
Modelo 720, the Spanish return on assets and rights held abroad, brings together in a single form three separate information obligations. Each has its own article in the Reglamento General de Gestión e Inspección (Royal Decree 1065/2007, the regulations on tax management and inspection) and its own limit:
| Block | What goes in | Article of the Regulations | Which figure is compared with 50,000 € |
|---|---|---|---|
| Accounts | Deposits with institutions engaged in banking or lending business | 42 bis | Balance on 31 December and, separately, the average balance for the fourth quarter |
| Securities, funds, insurance and annuities | Shares, bonds, units in collective investment schemes, life insurance, life or temporary annuities | 42 ter | Sum of the values of all those items on 31 December |
| Real estate | Real estate and rights over real estate | 54 bis | Sum of the acquisition values |
Each block is measured against its own threshold. A block that does not reach it stays out even if the others exceed theirs comfortably, and the other way round.
For Ingrid, the calculation works out like this:
- Accounts: 38,000 €. Below the limit. Unless the average balance for the last quarter went above 50,000 €, this block is not reported.
- Securities, funds and insurance: 29,000 € for the fund + 24,000 € for the policy = 53,000 €. Above the limit. The fund and the policy are reported.
- Real estate: acquisition value of 46,000 €. Below the limit, even though the flat is worth a good deal more today.
Result: Ingrid files the 720 for the second block only. She has 137,000 € abroad and reports 53,000 €. Had she read the threshold as one global figure, she would have reported too much; had she looked at each item on its own ("the fund doesn't reach it, nor does the policy"), she would have failed to report what she did have to.
Within each block, everything adds up
The opposite mistake is just as common as the first: looking at each account or each product in isolation. Within one block the amounts are added together. Three accounts of 20,000 € in three different banks in three different countries make 60,000 € in the accounts block, and then all three are reported.
In the second block the aggregation is more surprising, because it mixes things nobody thinks of together: a share portfolio with a broker, a fund, an ETF and a life insurance policy with a surrender value all add up. That is why many taxpayers end up obliged to file without owning any product that seems significant on its own. The detail of what falls under each code is in the guide to the three blocks of the 720.
And once the threshold is exceeded, the whole block is reported: not just what pushed the figure over, but also the leftover account with 300 € in it or the small bond you had almost forgotten. The Regulations say so expressly for each block: once the joint limit is exceeded, information must be given on all the items.
Accounts are checked against two figures
The accounts block is the only one with a double test. Article 42 bis exempts you from reporting only when neither the balances on 31 December nor the average balances for the last quarter exceed, taken together, 50,000 €. It is enough for one of the two figures to exceed the limit for all the accounts to be reported.
A worked example with Ingrid, assuming a different history for her Swedish account:
| Month | Month-end balance |
|---|---|
| October | 71,000 € |
| November | 64,000 € |
| December (31st) | 38,000 € |
If the average balance for the quarter, calculated day by day, is around 60,000 €, Ingrid is obliged to report the accounts block even though she only has 38,000 € on 31 December. Withdrawing money in December does not avoid the obligation.
It works the other way too: a balance that reached 90,000 € during the year but is below 50,000 € both in the last quarter and on 31 December does not trigger the obligation. What happens in March or July does not count for the threshold; what counts are the two reference points set by the Regulations.
Two clarifications from the criteria published by the Agencia Tributaria, the Spanish tax agency, in its frequently asked questions on the form: negative balances are offset against positive ones to see whether the threshold is exceeded, and an account on which you are only an authorised signatory also counts towards your accounts block.
Borderline cases
| Situation on 31 December | Obliged to file? | Why |
|---|---|---|
| One account of 49,500 €, average balance for the quarter 49,800 € | No | Neither figure exceeds 50,000 € |
| An account of 30,000 € and another of 21,000 € in another country | Yes, both | The block totals 51,000 € |
| Shares worth 48,000 € and an ETF worth 3,000 € | Yes, both | Both are in the same block |
| Property bought for 45,000 € that is worth 200,000 € today | No | What counts is the acquisition value, not the market value |
| An account with 60,000 € and an overdraft of 12,000 € on another | No | Net 48,000 €, provided the average balance is also below the limit |
| 49,000 € in accounts, 49,000 € in securities and a property of 49,000 € | No | Each block is taken separately |
The last row is the hardest to accept: 147,000 € outside Spain and no obligation to file the 720. It is correct, and there is nothing odd about it. It is another matter that those assets still count for your income tax and, where relevant, for the Impuesto sobre el Patrimonio (Spanish wealth tax), which have their own rules.
What the threshold does not affect
Being below 50,000 € in every block means not filing the 720 that year. It means nothing more:
- the interest, dividends and gains from those assets are still declared in your IRPF (Spanish personal income tax) return;
- wealth tax looks at your entire net worth, with its own valuation rules;
- cryptocurrencies held with a custodian abroad have their own form, Modelo 721, with its own threshold (we explain it in whether cryptocurrencies go in the 720).
The threshold is checked every year with that year's values. A fund that has risen or an account that received the proceeds of a sale can push a block from 46,000 € to 55,000 € without you buying anything new. Checking the December balances every January avoids finding out too late.
If you are unsure which block a particular product falls into, you can describe what you hold in the Modelo 720 form and we will review it with the statements in front of us before deciding whether or not you need to file.
When you are under the limit this year but were over it before
There is an in-between situation: having reported a block in an earlier year and being below 50,000 € today. There, the question is no longer the initial threshold but the rule on increases of 20,000 € and the obligation to report what is sold or closed. If that is your case, read on in I have filed it once before and in the guide on when the 720 has to be filed again.
What to have in front of you to decide
Checking the threshold properly takes only a few documents, but they must be exact:
- the certificate of the balance on 31 December and the average balance for the fourth quarter of each account, which the bank usually issues if you ask for it;
- the tax report or year-end valuation from the broker, the fund manager and the insurer;
- the deed or purchase contract for each property, with the taxes and costs of acquisition.
With those, each item is placed in its block and the result follows on its own. What is unwise is to decide from memory: the difference between 49,000 € and 51,000 € usually lies in a product nobody remembered.
This question is part of the work we do at Salama Tax with residents who hold assets abroad: that page explains how the form is prepared, what documents we ask for and how it fits with each year's income tax and wealth tax.