The deadline for filing Form 720 (Informative Declaration on Assets and Rights Located Abroad) for the 2025 tax year is March 31, 2026.
What is meant by assets and rights located abroad?
For the purposes of this informative declaration, they are divided into three groups:
Group 1: Accounts with financial institutions located abroad, including:
a. Current and savings accounts.
b. Term deposits.
c. Credit accounts and any other monetary accounts or deposits, regardless of their type or name, even if they do not generate remuneration.
Group 2: Securities, rights, insurance policies, and income deposited, managed, or obtained abroad, including:
a. Securities or rights representing an interest in any type of legal entity.
b. Securities representing the lending of capital to third parties.
c. Securities entrusted for management or administration to any legal instrument, including trusts or estates which, although lacking legal personality, may participate in economic transactions.
d. Life or disability insurance policies in which the taxpayer is the policyholder as of December 31 of each year, when the insurance company is located abroad, indicating their surrender value as of that date.
e. Temporary or life annuities of which the taxpayer is the beneficiary as of December 31, resulting from the transfer of monetary capital, economic rights, or movable or immovable property to entities located abroad, indicating their capitalization value as of that date.
Group 3: Real estate and rights over real estate located abroad, including:
a. Real estate of any type, whether rural or urban.
b. Timeshare arrangements, fractional ownership, part-time ownership, or similar arrangements.
c. Rights of use or enjoyment over real estate and bare ownership.
Who is required to file Form 720?
The following holders of assets and rights located abroad who do not have their value recorded individually and duly identified in their official accounting records:
• Natural persons and legal entities resident in Spanish territory.
• Permanent establishments in Spanish territory of non-resident individuals or entities.
• Individuals involved in an undivided inheritance, joint property estates, and other entities which, although lacking legal personality, constitute an economic unit or a separate pool of assets subject to taxation in Spanish territory.
This obligation also applies to individuals who, without being the holders of the assets or rights, are beneficiaries, authorized persons, or otherwise have powers of disposal over them, or who are their beneficial owners.
How can I know if I am required to file Form 720?
There is an obligation to file Form 720 when the following circumstances apply:
You or your entity are among the obligated parties listed in the previous section.
You are not a resident in Spain under the Special Regime for Posted Workers (also known as the Beckham Law).
The total value of each group of assets and rights exceeds €50,000 as of December 31. In the case of bank accounts, the average balance during the last quarter of the year must also be taken into account for these purposes.
If Form 720 was filed for the 2024 tax year (filed in March 2025), a new filing is required when the balance of any of these groups as of December 31, 2025 has increased by more than €20,000.
A filing is also required when, even if the declaration for 2024 was not required and the balance of any of these groups has not increased by more than €20,000 as of December 31, 2025, you ceased at any time during the 2025 tax year to be the holder, beneficiary, authorized person, person with powers of disposal, or beneficial owner. Circumstances that may result in the loss of such status include the disposal, liquidation, transfer, assignment, exchange, swap, or any other form of transfer of assets and rights located abroad.
What happens if I am required to file Form 720 for the 2025 tax year and I fail to do so? What if I was required to file it in 2024 and did not?
For late filing without a prior request from the Tax Authorities, the minimum penalty is €150, or €10 for each piece of information or set of data relating to the same person or entity that must be reported, with a maximum penalty of €10,000.
If the late filing occurs after receiving a request from the Tax Authorities, the minimum penalty is €300, or €20 for each piece of information or set of data relating to the same person or entity that must be reported, with a maximum penalty of €20,000.
It is also important to note that filing Form 720, when required, establishes the date from which the taxpayer has owned the assets and rights declared. This is particularly relevant when those assets or rights are later liquidated or transferred, and their value is realized in another type of asset incorporated into the taxpayer’s wealth (such as funds in a bank account, deposits, securities, real estate, personal property, vehicles, jewellery, etc.).
If Form 720 was required but not filed, the Tax Authorities may determine that the assets obtained through the liquidation or transfer of those assets and rights correspond to undeclared income generated during the last non-statute-barred tax year.
In such cases, the Tax Authorities may consider that the value of the asset incorporated into the taxpayer’s wealth corresponds to income generated and not declared five years prior to its incorporation. Consequently, they may assess a tax reassessment for the corresponding tax (whether Personal Income Tax or Corporate Income Tax), including:
the tax that should have been paid five years earlier,
late-payment interest accrued during those five years, and
the corresponding penalty for failure to pay the tax debt within the required period, calculated on 50% of the unpaid amount.
