What is Modelo 720?
Modelo 720 is an informational declaration — not a tax return — that Spanish tax residents must file if they hold assets abroad above a certain value. You're reporting what you own, not paying additional tax on it. But failing to file can still result in penalties.
The form covers three categories of foreign assets:
Bank accounts
held outside Spain
Securities, investments, insurance policies, and annuities
held or managed outside Spain
Real estate and property rights
located outside Spain
The threshold that triggers the filing requirement applies per category, not in aggregate. A Spanish tax advisor can tell you whether your specific situation crosses the line.
Who has to file?
The filing obligation applies to Spanish tax residents — generally, people who have lived in Spain for more than 183 days in a calendar year. Being a US citizen doesn't exempt you.
If you're living in Spain and still have significant assets in the US — retirement accounts, a brokerage account, a home you haven't sold — there's a good chance Modelo 720 applies to you.
What about joint assets?
If you hold assets jointly with a spouse or partner, both owners generally need to declare the asset and indicate their ownership percentage. This catches many people off guard.
Beckham Law recipients
If you're benefiting from Spain's Special Expat Regime (the Beckham Law), you're taxed as a non-resident during those years, which means Modelo 720 generally doesn't apply to you during that period. Once the regime ends and you become a regular tax resident, the obligation kicks in.
What counts as a reportable asset?
For Americans, the assets that most commonly come up include:
Social Security is generally not reportable, as it's a government benefit rather than an asset you hold.
Cryptocurrency held on foreign platforms has its own separate declaration form in Spain (introduced in 2024), distinct from Modelo 720.
Worth remembering: what's reportable in your specific situation depends on the value of those assets and which categories they fall into — another reason to work through this with a professional the first time.
When do you have to file?
The filing window runs from January 1 through March 31 each year, covering assets held as of December 31 of the prior year.
Once you've filed your initial declaration, you generally don't need to file again unless the value of a category increases significantly or you sell or close a previously declared asset. Your accountant can tell you what the specific thresholds are.
How to file
Modelo 720 is filed electronically through Spain's tax agency (Agencia Tributaria), and you'll need a digital certificate or Cl@ve PIN to access the system.
Most American expats work with a Spanish tax advisor — a gestor or asesor fiscal — especially for the first filing, when gathering everything and understanding what needs to be included takes the most effort.
The US reporting layer
As a US citizen, you also have foreign asset reporting obligations back to the United States. Your Spanish bank accounts, for instance, are “foreign” from the US perspective, and may need to be reported separately to the IRS and FinCEN depending on their value — the same FBAR and FATCA obligations covered in our US tax guide for Americans in Spain.
The key thing to understand is that these two systems run in parallel: Spain wants to know about your foreign (US) assets, and the US wants to know about your foreign (Spanish) assets. As an American living in Spain, you may have obligations on both sides.
The exact thresholds and forms involved on the US side are something a US expat tax specialist can walk you through — the rules differ depending on your filing status and whether you file jointly.
Getting help with Modelo 720
For most Americans moving to Spain, Modelo 720 is one of the first signs that Spanish tax compliance is more complex than expected. The interaction with US reporting requirements, the treatment of US retirement accounts, and the joint asset rules all create room for mistakes.
The right move is to get it done correctly from the start. A Spanish accountant who works regularly with American clients will know exactly what to look for.
Connect with a vetted accountant in Spain.
Tax laws change. This article is for general awareness only and is not tax or legal advice. Always consult a qualified professional before making decisions about your filing obligations.