Do I need to report my bitcoins in Form 720?

In respect of the obligation to report cryptocurrencies in the Informative Declaration of assets and rights located outside of Spain (Form 720), articles/studies that have been published conclude the following:

  • Cryptocurrencies are based on cryptography and on the blockchain, which is a single record, agreed and distributed in several nodes of a network (that is, it would be like the accounting book in which transactions are recorded). Consequently it would be difficult to determine where the cryptocurrencies are located.
  • Cryptocurrencies do not have a fit in any of the three blocks of assets/rights about which there could be a reporting obligation. Obviously they are not real estate.
  • On the other hand, the wallet is not considered an account in a financial institution. And finally, even though there is a figure of exchange houses that can manage the exchange of cryptocurrencies, in no case is there a transfer of our funds to these exchangers.

Thus, in relation to Model 720, there will be no obligation to report on investments in cryptocurrencies.

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