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.