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Form 720

Form 720: assets held abroad

Four independent blocks, a threshold of €50,000 in each and a repeat rule that almost everybody works out wrongly. And no, the 720 was not struck down: what the Court of Justice of the European Union struck down was its penalty regime.

Worked out from your own invoicesWith the detail behind every boxWithout typing anything in again
At a glance
What it declaresAssets and rights outside Spain
WhoPeople tax resident in Spain
How oftenAnnual, where applicable
Threshold€50,000 per block
Virtual currenciesForm 721

What form 720 is

Form 720 is an informative return on assets and rights located abroad. Nothing is paid for filing it: you are reporting.

It is organised into four blocks that are four independent obligations, each with its own threshold of €50,000:

  1. Accounts at financial institutions.
  2. Securities, insurance and annuities: shares, funds, life insurance policies with a surrender value.
  3. Property and rights over property.
  4. Virtual currencies, which since 2023 go on a form of their own, the 721.

Who has to file it

Anyone tax resident in Spain who goes over the threshold in any of the blocks. And there are three rules that are systematically applied wrongly:

One: for accounts, two balances are looked at

Not only the balance at 31 December, but also the average balance for the last quarter. It is enough for one of the two to go over €50,000 for the whole block to have to be declared, including the accounts with twenty euros in them.

Two: it is not split by share

Each joint holder counts the whole amount, not their share. That is why a married couple with a joint account of €60,000 both have to file, and almost nobody knows it.

Three: the €20,000 rule is not measured against the previous year

Once you have filed, you only have to declare again if the block has gone up by more than €20,000 compared with the last return filed — not compared with last year — or if you have lost ownership of an asset you declared. You can go five years without declaring and have to do it in the sixth because it has built up.

Deadlines

When the 720 is filed

With the weekend shifts already applied: when the last day falls on a Saturday, a Sunday or a public holiday, the deadline ends on the next working day.

PeriodDeadlineNote
Full tax year1 January → 31 MarchThe same deadline for the 720 and for the 721

It pays to start in January and not in March: asking a foreign bank for the average balance of the last quarter is not something you sort out in an afternoon.

What the Court of Justice of the European Union actually struck down

It is the most widespread myth about this form, and it is worth clearing up precisely.

The judgment of 27 January 2022 declared three consequences of non-compliance contrary to the free movement of capital, not the obligation to declare:

  1. The classification of undeclared assets as unjustified capital gains attributable to the oldest year still open, with the practical effect of making the obligation subject to no limitation period at all.
  2. The proportional fine of 150% on the tax due.
  3. The disproportionate fixed fines.

Spain implemented it with Ley 5/2022, which repealed those penalties and referred the matter to the general regime for formal infringements. That is:

The 720 is still compulsory, and there are still penalties, only now the general ones, which are very much smaller than the old ones. Anyone who stopped filing it because “Europe threw it out” has a problem waiting for them.

The exemption for assets carried in the accounts

There is one situation that matters a great deal to companies: assets recorded individually and identifiably in the accounts of their holder do not have to be declared on the 720.

For an account, that means having it in the accounts with its number, its institution, its branch and its country. It is the one point where keeping the books properly has a direct effect on a reporting obligation.

Watch out for this

The mistakes that come up most on the 720

The 720 goes wrong through arithmetic, not through bad faith.

Looking only at the balance at 31 December

For accounts there are two figures, and it is enough for the average balance of the last quarter to go over €50,000 for the obligation to arise, even if the year-end balance does not reach it.

Splitting the balance between joint holders

It is not split: each holder counts the whole amount. That is what makes both members of a married couple with a joint account have to declare.

Measuring the increase against the previous year

The €20,000 increase is measured against the last return filed, however far back that is. A year without an obligation does not reset the count.

Believing the 720 was struck down

What was struck down was the penalty regime and the absence of a limitation period, not the obligation. You still have to declare and there are still penalties, the general ones.

Screenshot of the ERP: the form 720 screen

modelo-720.png · 1400×900 px

Form 720 worked out in Cairos. Every box opens up to show which documents make it up.
In Cairos

Where every number on the 720 comes from

Nothing has to be typed in again: the form is worked out from the invoices and the expenses you have already entered during the period.

  • Each block is worked out separately, with its own threshold.
  • For accounts, both figures are kept: the year-end balance and the average balance for the last quarter.
  • The amounts go in whole, not split by percentage of ownership.
  • The software keeps the baseline of the last return filed, which is what makes the €20,000 rule come out right.
  • And it flags the closures: cancelling an account you declared creates an obligation even if no threshold is passed.

And you can open any box

Every amount on the form can be expanded to see exactly which invoices and which expenses make it up. That is what turns a figure into something you can defend if you are asked.

The 720 comes out of what you have already entered

Free plan forever, no card needed.

Questions about form 720

€50,000 in each of the blocks, counted separately. Having €40,000 in accounts and €40,000 in funds means you do not have to declare either of them, because they are not added together.
No. The judgment of January 2022 struck down three consequences of non-compliance — the absence of a limitation period, the 150% fine and the disproportionate fixed fines — not the obligation to declare. It is still compulsory and there are still penalties, the general ones.
Only if the block has gone up by more than €20,000 compared with that return — not compared with last year — or if you have lost ownership of an asset you declared. That is the rule most often worked out wrongly.
On the 721, which is a form of its own for virtual currencies, with the same deadline. And only if they are held by a custodian: a self-custodied wallet does not go there.
Yes. For bank accounts, being an authorised signatory creates the obligation too, even if the money is not yours and even if you have never touched it. It is one of the most surprising things about this form.

This page is for information and is reviewed whenever the legislation or the calendar changes. It does not replace your accountant: for your own case, ask someone who knows your numbers.

So the 720 stops taking an afternoon

If the invoices and the expenses are in, the form is already done.

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