Preguntas frecuentes2021-11-30T12:21:56+01:00

Form 720 Spain: frequently asked questions

We’re here to help you with all your queries regarding Form 720 Spain

Two or three obligations within the same form

If I find myself in the situation of having to declare several different assets, can I include them all in the same form?2020-07-14T15:10:13+02:00

Yes. You can use one form to declare two or three types of blocks of assets, without having to submit a new Form 720 Spain for each one.

Submission date

If I submitted Form 720 Spain last year, do I have to do it again this year?2020-07-14T15:09:48+02:00

If in comparison to last year’s form there has been an increase of more than 20,000 euros regarding the combined limit for each block, then you have to submit the form again this year. If the increase is less than 20,000 euros or there is a decrease, you won’t have to submit it again.
If your Form 720 Spain is made up of several blocks, you only have to resubmit the block that meets the condition mentioned above.

Valuation of rights and assets

How do I value my securities, rights, insurances and income abroad?2020-07-14T15:10:31+02:00

These must be valued according to the balance at 31 December. However, you will come across certain exceptions, so it’s best you talk to our experts to be sure.

How do I value securities and rights representing my holding in a company?2020-07-14T15:09:20+02:00

This will depend on whether the securities representing your holding in a company’s share capital or own funds are traded on an organised market or not. The AEAT specifies the valuation category for each case.

What acquisition value should I declare for a property I have inherited or been donated?2020-07-14T15:09:01+02:00

The value will be the property value on the date it’s transferred to you.

Should I included in Form 720 Spain the securities I have sold and reinvested and which I no longer own?2020-07-14T15:08:43+02:00

No. You only need to declare the existing balances at 31 December. When you use the earnings from the sale of the securities for buying other securities or rights, these new ones will have to be declared provided they meet the relevant conditions

What exchange rate should I apply for a foreign bank account in a currency other than the euro?2020-07-14T15:08:17+02:00

You must use the exchange rate on 31 December.

What exchange rate should I apply if I’ve closed the current account before 31 December?2020-07-14T15:07:18+02:00

If you happen to be obliged to declare the current account that has been closed, the balance will be converted at the exchange rate on the day it is closed.

What exchange rate should I use to convert into euros the value of a property abroad that’s in my name or in my company’s name?2020-07-14T15:06:58+02:00

You must use the exchange rate on 31 December of the year you are declaring.

Should I take into account an increase in the value of assets and rights due to exchange rates?2020-07-14T15:06:40+02:00

Yes. You will have to take into account these exchange rate increases, except when they affect real estate.
Real estate value is determined by the exchange rate on the purchase date and is exempt from subsequent changes due to exchange rate fluctuations.

What purchase date should I use if I initially gain bare ownership of a property located abroad and then gain full ownership at a later date?2020-07-14T15:03:41+02:00

The purchase date will be when you gain full ownership. The purchase value is the result of calculating the value of the initial real right and the value of consolidating the ownership.

What amount should I report in Form 720 Spain if I have shared ownership of an asset with others, but we didn’t acquire it on the same date or for the same amount?2020-07-14T15:03:16+02:00

You must declare the percentage of your holding, grossing up the purchase value. If you don’t know the purchase value paid by the rest of the owners, the full value may differ for each owner, in which case some of the owners may have to declare it and others may not.

Should I include the taxes and expenses associated to buying a property?2020-07-14T15:02:52+02:00

Yes. The purchase price should include all expenses strictly related to buying the property and the related taxes.

When reporting a global or custody account containing different types of assets that are identified by different codes, i.e. ISIN, should I do it individually or jointly?2020-07-14T15:06:22+02:00

Individually. You must report these individually as these assets could entail different obligations and would therefore be included in different blocks.

Obligation to submit

Do I have to include in Form 720 Spain a jointly owned bank account abroad with more than 50,000 euros at 31 December?2020-07-14T15:02:34+02:00

Yes. It must be declared regardless of the number of account holders provided you are not exempt from the obligation. You must declare the total value and indicate your ownership percentage.

Do I have to include in Form 720 Spain a jointly owned property abroad worth more than 50,000 euros at 31 December?2020-07-14T15:02:07+02:00

Yes. It must be declared regardless of the number of joint owners provided you are not exempt from the obligation. You must declare the total value and indicate your ownership percentage.

Should I report my assets abroad as an individual resident in Spain, performing an economic activity in Spain and keeping accounts according to the Code of Commerce?2020-07-14T15:01:43+02:00

This will depend on the type of asset.
In the case of securities, rights, insurances and income abroad, you must declare them in Form 720 Spain regardless of whether they are registered in your accounting records.
For real estate and bank accounts abroad, you don’t have to include them in Form 720 Spain when they are registered in your accounting records.

Do I have to submit Form 720 Spain as a legal entity which includes its assets and rights located abroad in its accounting records?2020-07-14T15:00:07+02:00

No. Legal entities don’t have to additionally declare any of the three blocks of assets and rights in their Form 720.

Should I include in Form 720 Spain a bank account abroad with a balance of 150,000 euros, of which I own 30% along with a resident company which owns the other 70%?2020-07-14T14:59:44+02:00

Yes. You must report your 30% ownership of a bank account abroad with a 150,000 euro balance.

If I submitted Form 720 Spain in 2017 reporting accounts abroad, but then in 2018 my authorisation over one of the accounts was revoked, should I declare this loss of authorisation in Form 720 Spain?2020-07-14T14:59:15+02:00

Yes. The Tax Agency requires that you report all authorisation revocations. You must report the date of the revocation, the existing balance on that date, identify the account and business or company name of the bank and its address.

Should I file a Form 720 Spain if I have never had the obligation to do so, but my ownership of an asset has been cancelled or suppressed?2020-07-14T14:58:46+02:00

No. Regardless of why you are not obliged to submit this form, you are not required to inform that you no longer own an asset.

Should I declare a pension plan I have taken out abroad?2020-07-14T14:57:58+02:00

No.

Should I declare it if I surrender the pension plan?2020-07-14T14:57:42+02:00

Yes. You must declare any income you collect.

Should I declare stock options?2020-07-14T14:57:24+02:00

No.

Should I also submit Form 720 Spain if I move abroad once the year has started and I am obliged to submit an income tax return?2020-07-14T14:57:00+02:00

Yes.

What if as a company I submitted Form 720 Spain to declare accounts abroad with a balance in excess of 50,000 euros and when I closed the account the balance was less than that amount, do I have to declare this in Form 720 Spain?2020-07-14T14:58:21+02:00

Yes. You are obliged to provide an informative statement regardless of whether the account balance is less than 50,000 euros.

If I live abroad, pay income tax in Spain and have a bank account domiciled in Spain but with a foreign institution, do I have to declare all this in Form 720 Spain?2020-07-14T14:56:37+02:00

Yes. You must submit Form 720 Spain, unless the institution is considered a tax resident in Spain and, therefore, this information has already been provided.

If I own an asset abroad but am not obliged to declare it, do the rest of the holders of these assets have to submit Form 720 Spain?2020-07-14T14:54:32+02:00

The rest of the real owners will be obliged to submit it depending on whether they meet the provisions of the regulation.

Should I include in Form 720 Spain if at 31 December I appear as the holder of a foreign bank account with a balance of 40,000 euros and I am also authorised on another account with a balance of 30,000 euros?2020-07-14T14:54:02+02:00

Yes. Except in the cases in which the regulation waives this requirement.

Should I include in Form 720 Spain if at 31 December I appear as the holder of a foreign bank account with a balance of 40,000 euros and I am also authorised on another account with a balance of 30,000 euros?2020-07-14T14:53:36+02:00

No, given that in this case you would be below the 50,000 euro limit.

Should I submit Form 720 Spain if I won the National Lottery in 2018 and invested the proceeds in buying a property abroad?2020-07-14T14:53:06+02:00

Yes. Provided the property meets the requirements provided in the regulation.

Do I submit Form 720 Spain if I am adhered to the Special Regime of Relocated Workers? Do my spouse and children have to submit it?2020-07-14T14:52:44+02:00

No.

Should I submit Form 720 Spain if I have a life insurance policy with a foreign insurer that operates in Spain under a regime of free provision of services?2020-07-14T14:52:28+02:00

No.

Does my spouse have to declare it if I am the holder of a matrimonial asset or right?2020-06-25T10:59:20+02:00

Yes.

What date should I use for calculating the value of assets abroad?2020-07-14T14:52:07+02:00

This depends on the type of asset, you can find more information on the AEAT website.

Should I submit Form 720 Spain if I am domiciled in the Basque Country or in Navarre, own assets abroad and am legally required to declare them?2020-07-14T14:51:50+02:00

Yes.

Who and how should it be declared if I am a partner in a Spanish resident company which has a stake in a non-resident company?2020-06-25T11:00:58+02:00

Provided the requirements are met, the resident company will have to perform the informative statement using Form 720.

What should I declare in Form 720 Spain if I am a controlling shareholder in a company not resident in Spain and I am also a non-controlling shareholder in another non-resident company?2020-07-14T14:50:59+02:00

You must declare your stake in the company where you are a controlling shareholder.

Should I submit Form 720 Spain if I own shares in a foreign company but these are deposited with a company constituted or established in Spain?2020-07-14T14:50:39+02:00

No.

Do I have to submit Form 720 Spain if I own a property abroad and have paid amounts on account when signing the deed?2020-07-14T14:50:22+02:00

No.

Do I have to declare accounts which have both negative and positive balances?2020-07-14T14:50:03+02:00

Yes.

Who should submit Form 720 Spain if a trust involves the transfer of assets abroad?2020-07-14T14:49:49+02:00

This will depend on the place of residence of the constituent, trustee and beneficiaries.

Does a company have to declare assets abroad in Form 720 Spain even if it isn’t obliged to maintain accounting records?2020-07-14T14:49:26+02:00

Yes. In this case, the only companies that are exempt from submitting Form 720 Spain are those that voluntarily maintain accounting records.

Should I use Form 720 Spain to report having a cash pooling account abroad?2020-07-14T14:49:04+02:00

Yes.

Do I use Form 720 Spain to report works of art, jewellery, cash, gold, boats, etc…?2020-07-14T14:48:46+02:00

No.

If I am a holder and authorised party on a bank account abroad, should I declare as the holder or as an authorised party?2020-07-14T14:48:16+02:00

As the holder.

If in 2018 I have the following assets: a) An apartment abroad that is sold halfway through the year for 100,000 euros; b) A bank account abroad with an average balance in the last quarter of 60,000 euros and a year-end balance of 42,000 euros; c) An investment fund valued at 55,000 euros. What assets should I declare in 2019?2020-07-14T14:47:51+02:00

You have to declare the investment fund and the bank account.

Do I have to submit Form 720 Spain if I own three properties in Germany with a total value of 47,000 euros and I sell one for 15,000 euros?2020-07-14T14:42:18+02:00

No.

Should I submit Form 720 Spain if I am the heir to a recumbent inheritance?2020-07-14T14:42:03+02:00

Yes, and you should declare the recumbent inheritance given that it is considered a company.

Do I have to submit Form 720 Spain if I am a co-owner of a community of owners that is obliged to submit Form 720 but has not included these specific assets abroad in its accounting records?2020-07-14T14:41:45+02:00

Yes.

Do I have to submit Form 720 Spain if I transfer securities to Spain that were previously abroad?2020-07-14T14:41:23+02:00

No.

Do I have to submit Form 720 Spain again if I sell securities that I had already declared in a previous Form 720 Spain?2020-07-14T14:41:11+02:00

Yes. You must submit Form 720 Spain to indicate that you no longer own the securities you have sold.

What happens if a person had declared assets abroad using Form 720 Spain and dies in 2018, does the form have to be submitted again in 2019?2020-07-14T14:40:13+02:00

Yes.

The form and how to fill it in

What Form 720 Spain fields do I have to fill in?2020-07-14T14:39:55+02:00

Tax code (NIF), full name or company name of the declarant, telephone number and name of the contact person.

What fields must I fill in that are common for all assets and rights that I need to report?2020-07-14T14:39:28+02:00

Subkey of asset or right, key of the declarant’s status, subkey of asset or right, type key of asset or right and country code.
In relation to the company address or location of the property: country code, percentage of ownership (except in the case of an authorised party) and origin of the asset or right.

What boxes do I have to fill in that are specific for declaring bank accounts abroad?2020-07-14T14:39:14+02:00

Account identification key, account code, entity identification, date of incorporation and valuations depending on the origin of the asset.

What boxes do I have to fill in that are specific for declaring bank accounts abroad?2020-07-14T14:38:47+02:00

Identification of the entity, identification key, identification of the securities, valuation 1, securities representation key and number of securities. However, the need to provide some of the above will depend on the key type (V or I).

What boxes do I have to fill in that are specific for declaring real estate abroad?2020-07-14T14:37:36+02:00

Date of incorporation, type key of the property, purchase value, transfer date, valuation 1 and 2. Yet the obligation to fill in these fields varies depending on whether it is an asset type A or C.

Can I get a draft of the Form 720 Spain declaration?2020-07-14T14:37:07+02:00

Yes.

Can I attach additional information to the Form 720 Spain declaration?2020-07-14T14:36:48+02:00

Yes.

Risks and penalties

What is the minimum penalty for not having submitted Form 720 Spain when I was obliged to declare the three types of obligations?2020-07-14T14:36:25+02:00

The minimum penalty is 30,000 euros.

What is the minimum penalty for not having submitted Form 720 Spain when I was obliged to declare one type of obligation?2020-07-14T14:35:47+02:00

The minimum penalty is 10,000 euros.

What would be the minimum penalty if my Form 720 Spain included four bank accounts abroad but had made mistakes or lied in each of them?2020-07-14T14:35:19+02:00

The minimum penalty would be 20,000 euros, i.e. 5,000 euros for each error, omission or false data.

What would be the minimum penalty if my Form 720 Spain included four bank accounts abroad but had made a mistake or lied regarding one figure?2020-07-14T14:34:46+02:00

The minimum penalty would be 10,000 euros, i.e. the minimum penalty that can be imposed.

Is there any way of checking whether Form 720 Spain coincides with the income already declared and regularise it if not?2020-07-14T14:34:19+02:00

Yes. Check out our blog on regularisation.

What omitted, mistaken or false data can lead to a penalty?2020-07-14T14:33:26+02:00

That will depend on each particular case, the Tax Agency details and specifies each case.

What happens if I submit Form 720 Spain after the deadline?2020-07-14T14:32:44+02:00

The penalties for late submission vary depending on each case, check out our blog for more information.

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