As part of Spain’s ongoing focus on tax transparency, certain taxpayers must continue to submit Modelo 720—an informative return reporting assets and rights held outside Spain. For assets held during the 2025 tax year, the filing window runs from 1 January to 31 March 2026.

For many international clients living or working in Spain, this annual obligation is a key compliance milestone. Modelo 720 is not a tax payment form; it is a disclosure requirement used by the Spanish Tax Agency to monitor foreign holdings.

 

Who needs to submit

You may be required to file Modelo 720 if you are tax resident in Spain (for example, if you spend more than 183 days in Spain in a calendar year, or if Spain is where your main economic interests are located) and you hold foreign assets exceeding the relevant thresholds.

Modelo 720 is divided into three separate reporting blocks:

• Bank and deposit accounts held with financial institutions outside Spain
• Securities, investments and rights (including shares, funds and certain insurance/annuity rights) held outside Spain
• Real estate and rights over real estate located outside Spain

Each block is assessed independently. A first-time filing is required where the aggregate value in any one block exceeds €50,000 as at 31 December 2025 (or the relevant reference values for that block).

 

What expats should watch

Many expats maintain international financial ties—such as overseas savings accounts, investment portfolios, pensions, or property abroad—which can trigger reporting obligations.

Key points to consider:

• Joint accounts and shared ownership: reporting can be required even where you only own part of the balance/value, depending on your legal position (e.g., holder/co-holder/authorised person) and the applicable rules for each block.
• Future filings: once Modelo 720 has been filed, it is generally only required again for a given block if the total value in that block increases by more than €20,000 compared with the last filing, or if assets are sold, cancelled, or otherwise cease to be reportable.
• Practicalities: preparation often requires year-end statements, correct valuation rules, and (where applicable) currency conversion into euros supported by appropriate documentation.

 

Non-resident considerations and the Beckham Law

Non-residents are not required to file Modelo 720. If your residency status changes, new obligations may arise—so early advice is recommended when planning a move to Spain.

For individuals taxed under Spain’s Special Regime for Inbound Workers (“Beckham Law”), Modelo 720 is generally not required, because the regime taxes the individual broadly as a non-resident for Spanish personal income tax purposes. However, eligibility and compliance can be fact-sensitive, and it is prudent to confirm your position in advance.

 

Why compliance matters

Although the penalty regime was softened following the Court of Justice of the EU’s findings on disproportionality, late, incomplete, or inaccurate filings can still lead to administrative penalties and increased scrutiny. Modelo 720 also interacts with other Spanish tax obligations, including personal income tax and (where relevant) wealth tax.

 

How we support our expat clients

We assist current and future expats with:

• determining whether Modelo 720 applies
• reviewing foreign asset categories, ownership positions and valuation approaches
• preparing and submitting the filing
• advising on related tax planning and compliance (including links with income/wealth tax reporting)

If you hold assets abroad or are planning to relocate to Spain, now is the right time to assess whether Modelo 720 applies—well ahead of the 31 March 2026 deadline.

For personalised guidance, our team is ready to help.