Modelo 720 is Spain's declaration of assets held abroad (Declaración de bienes y derechos situados en el extranjero). It is one of the most important tax compliance obligations for NLV holders who have foreign property, bank accounts, or investment portfolios, yet it is frequently overlooked until a penalty arrives. Here is what you need to know.
What Is Modelo 720?
Modelo 720 is an informational declaration — you are not paying any tax when you file it. Instead, you are telling the Spanish tax authorities (Agencia Tributaria) what assets you hold outside Spain. It must be filed by Spanish tax residents who hold foreign assets above certain thresholds.
Important: Modelo 720 is separate from your annual IRPF income tax return. It requires its own separate filing, on its own deadline. For a complete overview, see our Spanish tax obligations on the NLV. For a complete overview, see our NLV renewal.
Who Must File Modelo 720
You must file Modelo 720 if you are a Spanish tax resident (spending more than 183 days per year in Spain) and you hold foreign assets in any of the following categories above €50,000:
- Bank accounts held abroad — current accounts, savings accounts, term deposits at foreign banks
- Securities held abroad — shares, bonds, investment funds, pensions (certain types), and other securities held at a foreign broker or custodian
- Real estate held abroad — property you own outside Spain
The €50,000 threshold applies to each category separately. So if you have €40,000 in a UK bank account and €60,000 in a UK investment ISA, you must declare the securities (above €50,000) but not necessarily the bank account (below €50,000).
The Deadline
Modelo 720 must be filed between 1 January and 31 March each year, covering assets held as of 31 December of the previous year. So your 2024 assets (as at 31 December 2024) must be declared by 31 March 2025.
Subsequent filings are only required if:
- The value of any declared category has increased by more than €20,000 since the last declaration
- You acquire or dispose of assets in a declared category
- You failed to declare in a previous year
If nothing has changed significantly, you do not need to re-file every year once an initial declaration has been made.
What Assets to Include: A Practical Guide
- UK current and savings accounts — any bank account at a UK (or other foreign) institution
- ISAs — Individual Savings Accounts are foreign securities for Modelo 720 purposes. Stocks and Shares ISAs and Cash ISAs should be declared if above threshold.
- UK and US pension pots — defined contribution pensions held in foreign accounts may need to be declared. This area has some complexity — seek professional advice.
- Share portfolios at foreign brokers — US brokerage accounts, UK investment accounts
- Property abroad — holiday homes, rental properties, or your former main residence in your home country
Penalties for Non-Compliance
Penalties for Modelo 720 non-compliance were historically severe and challenged by the European Court of Justice. Following the ECJ ruling in 2022 (Case C-788/19), Spain reformed its penalty regime. Current penalties for late or incorrect Modelo 720 filing:
- Late filing (without investigation): €100 per data item, minimum €1,500
- Non-filing discovered during an audit: up to 150% of the estimated tax liability on undisclosed assets, though this is now disputed following the ECJ ruling
While the most disproportionate penalties were struck down by the ECJ, Modelo 720 remains a legal obligation and intentional non-disclosure still carries significant risk. File it correctly from your first year of Spanish tax residency.
How to File
Modelo 720 is filed online at the Agencia Tributaria website (agenciatributaria.es) using a digital certificate or Cl@ve PIN. The form requires:
- Your NIE number
- Details of each foreign account, institution, or property
- Balances as of 31 December (for accounts) or the acquisition date and value (for property and securities)
Most NLV holders use a gestor or tax adviser to file Modelo 720. The complexity of correctly categorising assets and calculating values across multiple currencies makes professional assistance well worth the cost (typically €150–400 for the filing).
Need help with Modelo 720 or Spanish tax compliance as an NLV holder? Contact My Spanish NLV — we can connect you with experienced Spanish tax advisers.