THE WAYPOINT SUR

About that old pension…
The financial archive you didn't pack
There is a pension scheme somewhere in the UK with your name on it. You have not thought about it since your last day in the office. Spain has.
The Modelo 720 — foreign asset declaration requires every Spanish tax resident to report foreign assets above €50,000 per category to the Agencia Tributaria — Spain's Tax Agency by March 31. No extensions. No exceptions.
What surprises people is not the form itself. It is the scope. "Foreign assets" does not mean the accounts you log into each month. It means the complete financial record of a professional life lived somewhere else.
What your career left behind
UK workplace pensions that are not yet in drawdown. This is the most common miss. A defined benefit scheme from a company you left in 2016. A SIPP accumulated across three roles. A deferred pension you have not looked at since the goodbye drinks. All of it counts. The threshold applies to the transfer value as of December 31, 2025, not the eventual income it will pay. Requesting that valuation from providers like Aviva, Legal & General, or Standard Life typically takes 10-14 working days. A request made after March 17 may not return in time.
UK ISAs. The principle is consistent across published guidance: Spain does not recognise the ISA wrapper. A stocks-and-shares ISA holds assets that Spain treats as a foreign securities account. A cash ISA is treated as a foreign bank deposit. If either category exceeds €50,000, the declaration obligation applies, and income generated inside the ISA (dividends, interest) is subject to Spanish savings tax on your Renta regardless of whether you withdraw it.
Where it gets less clean: we have heard from subscribers that different gestores have classified ISA types differently, and that the Agencia Tributaria has not always handled identical situations the same way. If you hold a substantial ISA, raise it explicitly with your gestor rather than assuming it falls one way or the other. This is precisely the situation where a generalist who has not encountered it before can make a call that creates problems later. (Confirmed March 2026)
Vested RSUs and share options. Anyone who held equity compensation in a corporate role and left those shares with the plan administrator upon relocation. Computershare. Equiniti. Morgan Stanley at Work. The login you have not used since your last day in the office. If the position is worth over €50,000, it is declarable.
Joint accounts. The obligation follows signing authority, not sole ownership. A joint account held with a spouse who is still a UK tax resident is not excluded if you are the Spanish tax resident in the household.
If you have filed before. The re-filing threshold is a value increase of more than €20,000 in any category, or the closure or sale of a reported asset. If nothing changed significantly, you can skip that year. The question is whether you captured everything correctly the first time.
The gestor question
Filing a 720 with UK assets is not a standard Spanish filing. The valuation of a defined benefit pension, the classification of different ISA types, the treatment of unvested equity: these require familiarity with UK financial products that most domestic gestores — tax advisors do not have.
Before you confirm your appointment, one question worth asking: ¿Ha trabajado antes con pensiones de planes de empleo del Reino Unido? — Have you worked with UK workplace pension schemes before?
Gestors who handle this well typically charge €200-400 for a 720 with complex UK assets, against €150-250 for a straightforward filing. The difference is worth paying if the alternative is an incomplete return. For those with significant worldwide assets, the same specialist will also understand whether Spain's Impuesto sobre el Patrimonio — wealth tax — applies to you based on your Andalucía residency and total asset picture. That is a separate calculation, but the same conversation. (Confirmed March 2026)
We need your help. Several of the gestores we have been comfortable recommending for foreign asset declarations are now fully booked for the season. If yours handled UK pensions, ISAs, or equity plans on a Modelo 720 and still has capacity, reply to this email with their name and contact. We are building a short list for readers who are still looking.
Go deeper
This newsletter covers what to declare. If you want the full picture on how the form works, what the current penalties are, and what the EU Court ruling in 2022 actually changed (and did not change), the full breakdown is here: → Modelo 720: The complete guide for expats
The 720 is not the only March deadline. If you want every filing date for 2026 in one place, including Renta, autónomo contributions, and the Modelo 721 for crypto assets: → Spain Expat Tax Deadlines 2026
Spanish-lite
Three terms that come up in this conversation:
Valor de rescate — transfer or surrender value (the figure used to assess a pension's declarable amount)
Fondo de pensiones — pension fund
Activos en el extranjero — foreign assets
The bottom line
The March 31 deadline covers everything you own abroad, not just what you actively manage. For anyone who moved to Spain mid-career, that includes the pension from a job held a decade ago, the ISA built across different life stages, and the equity that vested before the move. The Agencia Tributaria has automatic data exchange with HMRC and the SEC. The 720 is not how they find out about your assets. It is how you demonstrate that you disclosed them yourself. If your gestor is unfamiliar with UK financial products, the next fortnight is the time to find one who is not.
See you on the paseo — A. and the WaypointSur team with forgotten Computershare logins.
PS: If your gestor handled UK pensions, ISAs, or equity plans on a Modelo 720 and still has capacity for March, reply with their name and contact. We pass the good ones on.


