If you hold cryptocurrencies abroad, Spain now requires you to declare them through a new filing system. Many investors may not realise that coins stored on foreign exchanges or wallet providers fall under reporting obligations, even if the assets were never moved back to Spain. Understanding these rules is key to staying compliant.
Modelo 721, introduced in 2024, applies to anyone whose overseas crypto balances exceed €50,000. It was created to give the Agencia Estatal de Administración Tributaria (AEAT) better oversight of digital assets held outside the country. Filing may sound complicated at first, but knowing who must submit it, what details to include, and when the deadline applies can make the process far simpler.
What Is Modelo 721?
Modelo 721 is the official declaration used to report foreign cryptocurrency holdings. It was introduced to provide the AEAT with oversight of crypto assets stored outside Spain. Unlike tax forms that calculate payments, this is an informational form designed to improve transparency and prevent fraud.
The purpose of Modelo 721 is to inform the Spanish tax authority about crypto held abroad. It applies to assets stored on foreign exchanges, wallet providers, or custodians. By requiring this declaration, the government can monitor whether assets outside Spain align with reported wealth and income.
The obligation to report crypto abroad comes from Spain’s Anti-Tax Fraud Law of 2021. However, it became effective in 2023 with the passing of Royal Decree 249/2023 and Order HFP/886/2023. From 2024 onwards, investors must file Modelo 721 annually to declare balances exceeding the established threshold.
Also Read: Crypto Tax in Spain: The Ultimate Guide
Who Must File Modelo 721?
Not every crypto holder in Spain is required to file Modelo 721. The obligation applies only to those who meet specific conditions set by the AEAT. Understanding these requirements is crucial, as failing to file when you are eligible could result in penalties. Both residents and certain non-resident entities may be subject to this rule if they hold or benefit from cryptocurrency abroad.
Eligible Individuals and Entities
Modelo 721 must be filed by the following groups if they hold or benefit from crypto abroad:
- Individuals and legal entities who are residents in Spain.
- Permanent establishments of non-resident persons or entities operating in Spain.
- Inheritances in the process of settlement where the estate includes foreign crypto.
- Joint ownerships or communities of property with crypto holdings abroad.
- Other entities without legal personality that function as taxable economic units.
Conditions for Filing
You are required to file Modelo 721 if the following conditions are met:
- You are the holder, beneficiary, or authorised party of crypto stored abroad.
- You have disposal rights over cryptocurrencies held on foreign platforms.
- The combined balance of all foreign-held crypto exceeds €50,000 as of 31 December.
- Even if not actively used, significant holdings abroad must still be reported.
What Assets Need To Be Declared Under Modelo 721?
Not every type of crypto holding falls under the obligation of Modelo 721. The AEAT distinguishes between assets managed by third parties and those fully controlled by the holder. Knowing which categories require declaration prevents errors and ensures full compliance with Spanish tax rules.
Custody by Third Parties
If your cryptocurrencies are held by a foreign exchange, wallet provider, or custodian, they must be declared in Modelo 721. This includes both online custody through hot wallets and offline custody through cold wallets when managed by a third party. Since these providers control the private keys, the assets are considered to be abroad and fall under the declaration requirement.
Self-Custody Exemption
Holdings where you control the private keys yourself are not included in Modelo 721. Assets stored in hardware wallets, paper wallets, or offline devices managed solely by you are considered held in Spain, even if physically located abroad. This exemption is important, as many self-custody users do not need to report such assets under this form.
Fiat Currency in Foreign Exchanges
Modelo 721 applies only to virtual currencies, not fiat currencies. If you hold euros, dollars, or other fiat money in a foreign exchange account, they are not reported under this form. However, these balances may fall under Modelo 720, which covers traditional financial assets held outside Spain.
Information Required in Modelo 721
Filing Modelo 721 involves providing details about both the custodian and the crypto assets held abroad. The AEAT expects precise data to ensure transparency and traceability of digital assets. Inaccurate or incomplete submissions can lead to penalties, so understanding what information must be included is essential.
Identification of Custodian
When completing Modelo 721, you must fill in all the required details about the custodian holding your crypto abroad. This ensures that the AEAT can identify the entity responsible for safeguarding your assets. The following details must be provided:
- Full name of the custodian.
- Tax identification number of the entity, if available.
- Fiscal residence of the custodian.
- Address or official website of the exchange or wallet provider.
- Confirmation that the custodian controls the private keys to your crypto.
Identification of Cryptocurrencies
When declaring your crypto holdings abroad, each currency must be listed separately. The AEAT requires clear identification of every asset to avoid confusion or incomplete reporting. You must include the following details:
- Full name of the cryptocurrency.
- Symbol or abbreviation (for example, BTC for Bitcoin or ETH for Ethereum).
- Type of virtual currency, if there are variations, such as stablecoins or tokens.
- Declaration of each asset individually, not as a combined balance.
Valuation of Balances
When reporting balances in Modelo 721, the Spanish tax agency requires precise details to ensure accuracy. You must include:
- Total number of units of each cryptocurrency held abroad.
- Value in euros of those units as of 31 December.
- Valuation based on exchange rates from major trading platforms or recognised price trackers.
- If no exchange rate is available, use a reasonable market value estimate in euros as a substitute.
Filing Deadlines for Modelo 721
Submitting Modelo 721 on time is crucial to avoid penalties and remain compliant with Spanish tax law. The deadlines are strict, and late submissions can result in fines. Knowing when to file, how often, and under what circumstances re-filing is required helps taxpayers meet their obligations without difficulty.
First Filing Year
The first filing period for Modelo 721 applied to the 2023 fiscal year. Taxpayers had to submit the declaration between 1 January 2024 and 31 March 2024. This marked the beginning of annual reporting obligations for anyone holding foreign crypto exceeding the threshold.
Annual Obligation
From 2024 onwards, Modelo 721 must be filed every year during the period from 1 January to 31 March. The declaration covers crypto balances held abroad during the previous fiscal year, with values calculated as of 31 December.
When Re-Filing Is Required?
Even if you have already filed Modelo 721 in a previous year, you must re-file in two specific cases. First, if your combined crypto balance abroad increases by more than €20,000 compared to your last reported balance. Second, if you fully or partially liquidate your holdings before 31 December.
Penalties For Non-Compliance With Modelo 721
Failing to declare foreign cryptocurrency holdings through Modelo 721 can lead to strict penalties. The AEAT monitors these filings closely, and errors or late submissions are taken seriously. Understanding the consequences of non-compliance highlights why accurate and timely reporting is essential for anyone with assets abroad.
Types of Penalties
If you fail to comply with reporting obligations, the Spanish tax agency may impose the following fines:
- €300 for complete failure to submit the declaration when required.
- €150 for incorrect or incomplete submission.
- €20 for each undeclared record.
- €10 for each incorrectly declared record.
Expiry of Penalties
The duration for which penalties remain enforceable depends on the seriousness of the offence. The Spanish tax agency sets clear time frames for each category:
- Four years for minor infractions such as small errors or omissions.
- Five years for more serious tax offences involving significant reporting failures.
- Ten years for aggravated offences where there is deliberate fraud, concealment, or repeated non-compliance.
How Can KoinX Help With Crypto Holdings in Spain?
Declaring overseas crypto holdings can be time-consuming, especially with the strict rules around thresholds, custodians, and valuations. KoinX removes this burden by automating much of the reporting process, ensuring accuracy and compliance with Spanish requirements. It offers tailored tools to make filing simpler and error-free.
Automatic Tracking of Holdings Abroad
KoinX automatically tracks your foreign crypto balances across multiple platforms. By consolidating data, it ensures you always know if your assets exceed the €50,000 threshold. This proactive monitoring helps you avoid missed declarations.
Easy Integration with Global Exchanges
The platform integrates seamlessly with more than 800 exchanges, wallets, and blockchains. Whether your crypto is on a popular global exchange or a lesser-known service, KoinX collects and organises the information needed for accurate filing in Spain.
Generation of Spanish-Compliant Reports
KoinX prepares reports that follow the specific requirements of the Agencia Tributaria. These reports include valuations, custodian details, and asset breakdowns ready to be used when completing Modelo 721. This removes guesswork and ensures compliance with Spanish standards.
By using KoinX, you save time, reduce mistakes, and make declaring foreign crypto holdings stress-free. Start with KoinX today and stay fully compliant with Spain’s reporting rules.
Conclusion
Declaring foreign crypto holdings has become a critical part of compliance for Spanish residents. With Modelo 721 now in place, anyone holding more than €50,000 in overseas assets must disclose them accurately to avoid fines. Understanding the rules on custody, valuation, and deadlines ensures you remain on the right side of the Agencia Tributaria.
Instead of navigating these requirements alone, you can rely on KoinX. It tracks your holdings, integrates with exchanges worldwide, and generates Spanish-compliant reports. Sign up with KoinX today and simplify your foreign crypto declarations while ensuring full compliance.
Frequently Asked Questions
Do I Need To File Modelo 721 If My Crypto Is On A Spanish Exchange?
No, Modelo 721 only applies to cryptocurrencies held abroad. If your assets are stored on a Spanish exchange, they do not fall under this declaration. However, you must still report them for income tax and possibly wealth tax purposes if your total assets exceed the required thresholds.
Can I Be Penalised For Filing Modelo 721 Late But Accurately?
Yes, late filing can still result in penalties, even if the information is accurate. The AEAT enforces strict deadlines, and fines may be applied for delayed submissions. It is important to file between 1 January and 31 March each year to avoid unnecessary sanctions.
Are Stablecoins Included In The Modelo 721 Declaration?
Yes, stablecoins such as USDT or USDC are considered cryptocurrencies and must be declared if held on a foreign exchange or wallet provider. Their euro value as of 31 December should be calculated and reported in the same way as other digital currencies.
What Happens If My Foreign Crypto Balance Drops Below €50,000 Mid-Year?
If your balance exceeded €50,000 during the year but was below this limit on 31 December, you are still required to report the date when the balance fell below the threshold. This ensures that the AEAT has a complete record of your foreign crypto activity.
Do Minors Holding Crypto Abroad Need To File Modelo 721?
Yes, if a minor’s foreign crypto holdings exceed the €50,000 threshold, they are subject to the same reporting obligations. Parents or guardians are responsible for ensuring the declaration is filed on behalf of the minor to remain compliant with Spanish tax law.
Can I Use Average Prices For Valuation Instead Of December 31 Rates?
No, the AEAT requires valuations to reflect the 31 December rate from recognised trading platforms or price trackers. If such data is unavailable, you must use a reasonable market value estimate in euros. Average yearly prices are not accepted for reporting purposes.
Is Modelo 721 Linked To Wealth Tax Declarations?
Yes, the declaration complements wealth tax reporting. While Modelo 721 is purely informational, the details it provides are cross-checked with Modelo 714 if your assets exceed the regional wealth tax threshold. This helps the Spanish tax agency verify the accuracy of your total declared wealth.
