Spanish tax residents must declare foreign assets over €50,000 by March 31. The valuation date is December 31—fourteen days from now.

You're now a Spanish tax resident. If you spent 183 or more days here in 2025—or your center of economic interests is here—Spain considers you a resident for tax purposes. That triggers a reporting obligation most expats discover only when their gestor asks about it in spring.

The Modelo 720 — foreign asset declaration form — requires Spanish tax residents to report overseas assets exceeding €50,000. It's not a tax. It's an informative declaration. But the assets you report feed directly into your wealth tax and income tax obligations.

The deadline is March 31, 2026. The valuation date is December 31, 2025. You have fourteen days to document what you own abroad.

Three categories, measured separately:

Bank accounts: Current accounts, savings accounts, deposits, fixed-term accounts held outside Spain. If your combined foreign bank balances exceed €50,000 on December 31, you declare them all.

Securities and investments: Stocks, bonds, mutual funds, ETFs, 401(k)s, IRAs, UK pensions, life insurance policies, annuities. If your combined foreign investment value exceeds €50,000 on December 31, you declare them all.

Real estate: Property you still own in your home country. If the value exceeds €50,000, you declare it.

The €50,000 threshold applies per category, not combined. If you have €45,000 in a UK bank account and €200,000 in a US brokerage account, you declare only the securities category—the bank account is under the threshold.

But once any category exceeds €50,000, you report every asset in that category, regardless of individual size.

You're obligated if you're a Spanish tax resident AND you hold foreign assets exceeding €50,000 in any category. This includes:

Your US 401(k) counts. Your UK ISA counts. Your Vanguard account counts. Your Wise multi-currency account probably counts as a bank account if it holds € 50,000 or more.

The Agencia Tributaria — Spanish Tax Agency — has automatic exchange agreements with most Western countries. FATCA and CRS mean they already know what you hold abroad. The Modelo 720 is asking Spain to confirm it.

Your gestor files this form, but they need your data. Gestorías across the Costa del Sol will be swamped in February. Start now.

Currency conversion: All values must be reported in euros using the official ECB exchange rate on December 31, 2025. Your gestor handles this, but they need the foreign currency amounts.

Before 2022, Spain's Modelo 720 penalties were notorious—€10,000 minimum per undeclared asset, 150% of undeclared value. The EU Court of Justice ruled these "disproportionate" in January 2022.

The penalties have been reduced to standard administrative fines: roughly €20 per incorrect or missing data point, doubled for assets outside the EU. Late or incomplete filings are now in the €200-600 range for typical errors, not the €50,000+ penalties of the old regime.

But the obligation remains. Non-compliance triggers scrutiny. The Agencia Tributaria — Spanish Tax Agency — can reassess income tax if undeclared assets generated unreported income. The form itself isn't the penalty—it's what they find when they audit.

Once you've filed Modelo 720, you don't file again every year unless:

No significant change? No re-filing required for that category. Your gestor tracks this.

Two phrases for your gestor conversation:

"¿Necesito presentar el Modelo 720 este año?" — Do I need to file the Modelo 720 this year?

"Tengo inversiones en Estados Unidos. ¿Cómo afecta esto a mi declaración?" — I have investments in the US. How does this affect my declaration?

December 31 isn't just New Year's Eve. It's the date your foreign bank statements, brokerage positions, and property valuations must reflect for Spanish tax purposes.

If you're a Spanish tax resident with €50,000+ in any foreign asset category, you have until March 31 to file. But your gestor needs December 31 numbers. And December 31 is in two weeks.

Download your year-end statements now. Schedule a January meeting with your gestor. The form isn't complicated—but finding documentation in February when everyone else is scrambling is.

The filing window opens January 1. The deadline is March 31. No extensions available.

Reply MODELO720

If you're not sure whether your assets trigger filing—or you need a gestor referral who handles US/UK expat tax structures—hit reply with MODELO720 and a brief description of your situation. We'll point you in the right direction.

Onwards — A. and the thoroughly documented Waypoint Sur team

With Waypoint Sur, you can always expect plain-English guidance to land, settle, and thrive on the Costa del Sol—work, schools, healthcare, visas, taxes, home, and daily life.  
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