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V0848-26 21 April 2026 · SG de Tributos Criterion in force
IRPF · limited liability company

Duty to report ownership in foreign LLCs and overseas crypto custody

A Spanish resident asks whether they must declare their stake in a US LLC and crypto assets. The DGT clarifies that reporting of LLC shares (Form 720) and crypto assets (Form 721) is required if held by non-resident third-party custodians.

The question raised

Question raised

The DGT's ruling

Regarding cryptocurrencies, there is no obligation to file Form 721 if it concerns a self-custody wallet or if the balance is less than 50,000 euros. Regarding the participation in the LLC, there is an obligation to report via Form 720 if the 50,000 euro threshold is exceeded, valuing the participation according to the Wealth Tax rules for unlisted entities. The LLC, as it is not a resident in Spain, has no reporting obligation.

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