Form 720 is an information return, but it leaves little room for error: complete details, consistent supporting documents and the correct deadlines. When filing it, the ‘what’ is rarely the problem — it is the ‘how’. A mistyped IBAN, a wrong security identifier, an incorrect country code, or an inconsistent conversion into euros can trigger a request for information.
If you are tax resident in Spain and hold assets abroad (as an individual or through a company), this guide will help you understand whether it applies to you, what you must declare, and how to reduce the risk of mistakes.
What is Form 720, and why should you take it seriously?
Form 720 informs the Spanish Tax Agency of certain assets and rights located abroad that are linked to taxpayers resident in Spain.
The fact that it is ‘informative’ does not make it minor. In practice, risk arises when it is filed late, when assets are omitted within a block that exceeds the threshold, or when the declared information is not backed up by appropriate documentation.
Who it affects: not only the legal holder
In theory, it is straightforward: it is filed by those who hold assets abroad. In practice, Form 720 creates uncertainty because the obligation is not limited to the legal holder.
If you are tax resident in Spain, it may apply if you are the holder, but also if you act as a representative, authorised person, beneficiary, or you have powers of disposal or the status of beneficial owner. In international structures, this is not unusual — and it is a common source of doubt.
If you are uncertain at this point, it is worth stopping to check before going any further. Many Form 720 issues start at this boundary.
What you must declare: three blocks and one rule that prevents errors
Form 720 is structured in three sections. Understanding them is half the work, because the threshold is calculated separately for each one. Put simply: you assess the threshold by block, not by adding all assets together.
Block 1 covers bank accounts and deposits held with financial institutions abroad. Here, in addition to the balance at 31 December, the average balance for the last quarter is usually relevant.
Block 2 covers securities, rights, insurance policies and income held abroad: shares, funds, bonds, life insurance and temporary or lifetime annuities, among other products. The usual reference is the value at 31 December, but the amount is not the only key point: the product and the institution must also be correctly identified.
Block 3 covers real estate and rights over real estate located outside Spain (full ownership, usufruct, bare ownership, timeshare). Here, the acquisition value is usually declared, without indexation.
When you must file: €50,000 and the €20,000 rule
You must file Form 720 when the total value of the assets in any one of the three blocks exceeds €50,000.
If you exceed the threshold in a block, you must declare all assets in that block — not just the portion ‘above’ the threshold.
If you filed it in a previous year, it does not automatically repeat every year. In general, the obligation arises again when, within a block, the combined value increases by more than €20,000 compared with what was last declared, or when there are material changes that must be reported (for example, closures, disposals, or transfers).
This means you should review your international assets every year, even if ‘nothing seems to have changed’. Portfolio revaluations or additional contributions may trigger the obligation again.
Filing deadline and how to submit
As a general rule, Form 720 is filed between 1 January and 31 March of the year following the tax year to which the information relates. It is submitted online via the Spanish Tax Agency’s electronic office.
The difference is usually not the deadline, but the process. When it is filed quickly, with incomplete or unchecked documentation, avoidable errors multiply.
Common mistakes — and how to avoid them
Issues usually arise from errors in calculation, identification or valuation.
A frequent mistake is assuming there is no obligation because the balance at 31 December does not reach €50,000. For bank accounts, you must also check the average balance for the last quarter, and you must always assess the threshold by block.
Another common mistake is failing to file in later years when accounts are closed or previously declared assets are extinguished. Form 720 is not only for ‘new assets’: it must also reflect closures and changes.
It is also common not to file again when a block increases by more than €20,000 compared with the last declaration. A portfolio revaluation or a new acquisition may be enough for the obligation to arise again.
On top of this, there is confusion between Form 720 and Form 721 (crypto-assets held abroad). Filing one and assuming it covers the other is a mistake that should be avoided from the outset.
Then come the ‘form’ errors: a mistyped IBAN, the wrong ISIN, the wrong country, an incomplete address, or an incorrect classification within the form (codes and subcodes). They may look minor, but in an information return they carry weight.
Finally, amounts. The problem is often an incorrect exchange rate or using the wrong valuation criterion (31 December, average balance, and so on). One practical point deserves attention: keep certificates and supporting documents (balances, valuations, closing statements, or transfer evidence). If the Tax Agency issues a request for information, that documentation supports your filing.
How to prepare Form 720 without getting lost
If you follow one routine, make it this:
First, confirm that you are tax resident in Spain and review the three blocks separately to see whether you exceed €50,000 in any of them. If you have filed in previous years, add two checks: whether any block has increased by more than €20,000, and whether there have been material closures, disposals, or transfers.
Second, collect your documentation before you open the form. Do it by block, and take it step by step. The goal is not to gather paperwork, but to ensure every figure you declare can be supported by a certificate, statement or deed.
For accounts, obtain certificates showing the balance at 31 December and the average balance for the last quarter, ownership details and dates. For securities and insurance, gather statements as at 31 December, identifiers (ISIN or equivalent), number of units or shares, and details of the institution. For real estate, keep deeds or contracts, the acquisition value, the ownership percentage and the full address. In all cases, define the exchange-rate method you will apply to convert foreign currencies into euros.
Third, complete the form with a control table in front of you (even a simple spreadsheet). The point is not to improvise while you are inside the form. Before submitting, verify countries, dates and ownership percentages, and check that nothing has been missed within the relevant block.
Fourth, keep everything: the filed PDF, the receipt with the CSV code, and the supporting documentation behind the declaration.
Frequently asked questions to resolve before filing
Is the €50,000 limit calculated by adding up all assets? No. It is assessed by block: accounts; securities/insurance/income; and real estate.
Do I have to declare an account with a low or unused balance? If the accounts block exceeds the threshold, it is prudent to include all accounts in that block, even if some have a minimal balance.
If I am an authorised person or beneficiary, does it affect me? It may. It depends on your role in relation to the asset (powers of disposal, beneficial ownership, etc.) and how the arrangement is legally structured. This should be reviewed case by case.
When do I have to file again if I have already filed? When a block increases by more than €20,000 compared with what was last declared, or when there are material changes that must be reported (for example, closures or transfers).
Are cryptocurrencies declared on Form 720? No. Crypto-assets held on foreign platforms are declared on Form 721.
If you want to minimise risk, here is how Certus can help
Form 720 sits at the intersection of domestic and international taxation. What usually goes wrong is not the concept, but the execution: thresholds, identification, valuation and documentation.
If you need support, at Certus Legal Firm we can assist with assessing whether you must file, reviewing documentation, completing and submitting the form, and — where appropriate — voluntary regularisations.
If you would like us to review your case with you, you can check what our tax advice service includes and explore our tax practice area to understand our approach.
And if your situation involves international mobility — for example, if you have moved to Spain for professional reasons — you may also be interested in our article on the special tax regime for workers, professionals, entrepreneurs and investors relocating to Spain.
