Updated guide
What is the Modelo 720 and who must file it in 2026
Contents
- The three categories of foreign assets covered by the Modelo 720
- Deadlines, filing method, and relevant changes in 2026
- How the Modelo 720 affects your IRPF: savings base, dividends, and pension plans
- Capital gains and savings base brackets
- Foreign investment funds and transfer regime
- Pension plans and the 2026 limit
- Practical example: a taxpayer with an account and funds abroad
- Sources and reference legislation
# What is the Modelo 720 and who must file it in 2026
The Modelo 720 is the informational declaration of assets and rights located abroad that must be filed by tax residents in Spain. The obligation exists when the total value of the assets in any of the three legal categories exceeds 50.000 euros as of December 31 of the previous fiscal year. In 2026, the filing deadline corresponds to assets held as of December 31, 2025, and the filing window runs from January 1 to March 31, 2026, as established by the Order HAP/72/2013 and its subsequent modifications published in the BOE.
If you do not exceed this threshold in any category, you are not required to file the model. If you already filed it in previous years and the value of your assets has not changed by more than 20.000 euros compared to the last declaration filed, you are also not required to file again.
The three categories of foreign assets covered by the Modelo 720
The regulation groups assets into three independent blocks. The threshold of 50.000 € applies to each block separately, not to the total overall:
- Bank accounts in foreign financial institutions. Includes current accounts, savings accounts, time deposits, credit accounts, and any other account or deposit. The balance as of December 31 and the average balance of the last quarter of the year are considered.
- Securities, rights, insurance, and pensions held, managed, or obtained abroad. This includes shares, participations in foreign investment funds, life or disability insurance contracts with non-resident insurers, and annuities. It is relevant for those with investment funds domiciled outside Spain: the transfer between foreign funds does not exempt from the obligation to declare if the threshold is exceeded.
- Real estate and rights over real estate located abroad. The acquisition value is declared.
Each category is analyzed independently. You can have 80.000 € in accounts and 30.000 € in real estate: you would only be required to declare the first category.
Deadlines, filing method, and relevant changes in 2026
The Modelo 720 is filed exclusively electronically through the Tax Agency (AEAT) electronic portal, using a digital certificate, DNI electrónico, or Cl@ve PIN. There is no paper filing.
Deadline: January 1 to March 31, 2026, for assets as of December 31, 2025.
A critical point: after the Court of Justice of the European Union (CJEU) ruling in January 2022 and the subsequent legislative modification included in Law 5/2022, the sanction regime for the Modelo 720 was reformed. The disproportionate sanctions that existed previously were eliminated. Currently, non-compliance is sanctioned under the general tax infringement regime of the General Tax Law, with fixed fines of 200 euros per omitted or incorrect data (minimum 1.500 euros for a late declaration without prior notice), according to the current wording. Always consult the updated version in the BOE or the AEAT portal, as the sanctioning regulation may have had subsequent regulatory developments.
Important: Filing the Modelo 720 is informational. It does not generate a tax debt on its own, but the declared data may be cross-checked with other tax obligations, especially with the IRPF savings base and the Wealth Tax.
How the Modelo 720 affects your IRPF: savings base, dividends, and pension plans
Declaring assets abroad has direct implications on other tax obligations that you should be aware of.
Capital gains and savings base brackets
The interest from foreign bank accounts, dividends from foreign shares, and the income from life insurance contracts signed outside Spain are taxed as capital gains and are integrated into the IRPF savings base. In 2026, the savings base brackets according to the state regulation are, in general:
- Up to 6.000 €: 19%
- From 6.000 € to 50.000 €: 21%
- From 50.000 € to 200.000 €: 23%
- From 200.000 € to 300.000 €: 27%
- Over 300.000 €: 28%
Note: autonomous tax rates may modify the final result. Check the applicable brackets in your autonomous community and the fiscal year in the AEAT.
The IRPF dividend rate you receive from foreign companies follows the same structure. If a German company pays you 8.000 € in dividends, the first 6.000 € are taxed at 19%, and the remaining 2.000 € at 21%. Additionally, you must review if there is a double taxation treaty with the country of origin to avoid double taxation.
Foreign investment funds and transfer regime
One of the most common errors is assuming that the tax deferral regime for fund transfers applies equally to funds domiciled outside Spain. The transfer regime without immediate taxation (Article 94 of the IRPF Law) applies to collective investment institutions (CIIs) established in the EU and registered with the CNMV, but with nuances. If the fund does not meet the requirements, the refund is taxed in the year it occurs, integrating into the savings base.
Pension plans and the 2026 limit
Foreign pension plans may also be subject to declaration if they are structured as economic rights managed by non-resident entities. The contribution limit to pension plans in 2026 with the right to a reduction in the general IRPF taxable base is, in general, the lesser of these two amounts: 1.500 euros annually or 30% of the net earnings from work and economic activities, according to the regulation in force included in the IRPF Law (Royal Decree-Law 3/2004 and subsequent modifications). Employment pension plans have additional limits. Consult the AEAT to confirm if there have been changes for the 2025 fiscal year that is declared in 2026.
Practical example: a taxpayer with an account and funds abroad
Situation: María is a tax resident in Spain. As of December 31, 2025, she has:
- A current account in a French bank with a balance of 62.000 € (average balance of the last quarter: 58.000 €).
- Participations in a Luxembourg investment fund valued at 35.000 €.
- An apartment in Portugal valued at 40.000 € (acquisition value).
Analysis by categories:
- Category 1 (accounts): 62.000 € → exceeds 50.000 € → required to declare.
- Category 2 (securities/funds): 35.000 € → does not exceed 50.000 € → not required.
- Category 3 (real estate): 40.000 € → does not exceed 50.000 € → not required.
Result: María must file the Modelo 720 before March 31, 2026, declaring only the French bank account. Additionally, the interest generated by this account in 2025 must be included in her 2025 IRPF declaration (filed in 2026) as capital gains, integrating into the savings base.
If the following year the Luxembourg fund rises to 55.000 €, María will need to declare Category 2 in the 2027 Modelo 720.
Sources and reference legislation
- Tax Agency (AEAT): Electronic portal for filing the Modelo 720 and consultations — www.agenciatributaria.es
- BOE: Order HAP/72/2013, of January 30, approving the Modelo 720; Law 5/2022, of March 9, modifying the sanction regime.
- Law 35/2006, IRPF and its Regulation (RD 439/2007): Regulation of the savings base, capital gains, and investment fund regime.
- Law 58/2003, General Tax Law: Infringement and sanction regime applicable after the 2022 reform.
- CJEU: Judgment of January 27, 2022 (Case C-788/19), which declared the original sanction regime incompatible with EU law.
- Double taxation treaties: Available on the AEAT website, section "International Taxation".
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Preguntas frecuentes
What happens if I don't file the Modelo 720 when required?
After the reform introduced by Law 5/2022, non-compliance with the Modelo 720 no longer carries the disproportionate sanctions that existed previously (which were declared contrary to EU Law by the CJEU in January 2022). Currently, the general regime of the General Tax Law applies: a fixed fine of 200 euros per omitted, incomplete, or inaccurate data set, with a minimum of 1,500 euros if the declaration is submitted late without prior administrative request. If there is a prior request, the minimum increases to 2,500 euros. Additionally, the AEAT may cross-reference the information with other declarations and detect undeclared income in the IRPF or the Wealth Tax, which may lead to additional liquidations with delay interest and penalties for unpaid amounts.
Do foreign investment funds have the same tax treatment as Spanish ones in the IRPF?
Not necessarily. The tax deferral regime allowing the transfer of investment funds without taxation at the time of redemption applies to collective investment institutions (IIC) established in EU countries and registered with the CNMV, provided they meet the requirements of article 94 of the IRPF Law. If the foreign fund is not registered with the CNMV or does not meet these requirements, the redemption or sale of shares is taxed in the year it occurs, integrating the capital gain into the IRPF savings base at the applicable rates (19%, 21%, 23%, 27%, or 28% depending on the bracket). It is essential to verify the fund's status with the CNMV before assuming it applies to the transfer regime.
Do I have to file the Modelo 720 if I already filed it last year and my assets haven't changed much?
If you already filed the Modelo 720 in previous years, you are only required to resubmit it in the years when the value of assets in any category has increased by more than 20,000 euros compared to the amount declared in your last submitted declaration. For example, if you declared an account with 60,000€ and it now has 75,000€, the increase is 15,000€, so you wouldn't be required to resubmit for that category. However, if you acquire new foreign assets exceeding the 50,000€ threshold in any category, you must declare that category even if others haven't changed. In case of any doubt, consult directly with the AEAT or a tax advisor.
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