Informational content only; not tax or legal advice.
If you keep cryptocurrency with a custodian outside Spain (on a foreign exchange/provider), you may have to report it to the Spanish Tax Agency (AEAT) via Model 721. Below you’ll find who is required to file, when (deadlines), what data is needed, and how to prepare without unnecessary errors.
Model 721 is an informational return for virtual currencies held abroad (in custodial accounts with non-resident providers). Spanish tax residents (individuals and entities) must file if they are owners/beneficiaries/authorized persons or otherwise have disposal rights over coins that, as of December 31, are held with a foreign provider.
Important: this is specifically about custodial holdings with third parties. Self-custody (autocustodia)—where you control the keys—is not reportable under Model 721.
When the provider holding your keys (exchange/custodian) is not a Spanish resident and is not required to report in Spain. To understand a provider’s status, look at its jurisdiction/registrations.
Filing threshold: a €50,000 aggregate balance on December 31 across all virtual currencies held abroad. If you do not exceed the threshold, you do not file; if you exceed it, you report all positions.
Filing window: January 1 to March 31 of the year following the tax year.
Refiling: you file again only if your aggregate balance increases by more than €20,000 compared to the last return you filed, or if you cease to be obliged (e.g., you close positions)—in that case, you report the extinction (cessation) of the obligation for the year in question.
Information is provided for each coin separately:
Before logging into AEAT’s e-office:
Filing with AEAT:
Find the Modelo 721 procedure on the tax agency’s website, follow the on-screen steps, enter your pre-collected data, and upload supporting documents if requested.
Model 714 (Impuesto sobre el Patrimonio/Wealth Tax) is a separate obligation for taxpayers liable for the wealth tax. Check regional thresholds and rules.
MiCA and the provider list (CNMV): Spain is operating under a MiCA transition period. The CNMV publishes information about providers. This can affect who reports in Spain, but it does not remove your Model 721 obligation if your assets are custodially held with a non-resident provider.
Does Model 721 apply to Spanish exchanges?
Resident providers report in Spain themselves; Model 721 targets foreign custody.
Do I have to file Model 721 every year?
Only if your aggregate balance rises by more than €20,000 versus your last filing, or if you terminate the obligation (sale/closure).
What happens if I fail to file Model 721 when required?
You may face penalties and requests for information from AEAT. Minimize risk by preparing solid evidence and filing on time.
In 2025, Model 721 is a routine requirement for investors with custodial crypto held outside Spain. Remember three pillars: the €50,000 year-end threshold, the Jan 1–Mar 31 filing window, and per-coin, per-custodian reporting. With a well-organized evidence pack (CSVs, screenshots, provider details), filing becomes a straightforward process.
