Modelo 720 remains a separate reporting obligation. The former special penalty regime changed in 2022, but accurate classification, values and filing decisions still matter.
Reviewed and updated: 29 October 2026. The original publication date is retained above.
Modelo 720 reports certain assets and rights held outside Spain. It does not calculate an income-tax payment, but it requires a separate filing review.
The former special penalty regime was changed following the EU judgment and Law 5/2022. The old examples of automatic 150% penalties and disproportionate fixed fines should not be used as a description of today’s regime. AEAT now refers to the general penalty rules in Articles 198 and 199 of the General Tax Law.
Start with your status and the relevant asset categories. Then review the applicable thresholds, valuation rules, ownership or authority over the assets, and previous filings. A bank balance, investment statement and property document do not necessarily provide the same reporting information.
A previous return also matters. Changes in values, ownership or the assets themselves can affect whether another filing is needed. Reusing last year’s figures without reviewing what changed can lead to errors.
Keep the supporting records and identify the years involved. Review the information return alongside any separate income-tax or wealth-tax questions before deciding how to correct the position.
Explore Overseas Asset Reporting (Modelo 720) to discuss the documents and scope of a review.
Official source: AEAT: Modelo 720 penalties and effects.
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