Form 720: Correct Identification of the Entity and IBAN for Foreign Accounts

The correct completion of Form 720 is fundamental to avoid errors in the declaration of assets and rights located abroad. A recurring doubt arises when the entity with which the contractual relationship is maintained uses an associated or fiduciary bank to manage its operations, which generates uncertainty regarding which data to report.

What the DGT has ruled

The Directorate General of Taxes (DGT) has specified that the information regarding the financial institution and the BIC code that must appear on the form are those corresponding to the entity with which the taxpayer has contracted the account. The information of the associated bank linked to the BIC code should not be used; instead, the information of the entity with which the direct contractual link exists must be used.

Regarding the account number, the DGT establishes that the IBAN code to be declared will be the one assigned to the client's settlement account. This criterion is based on the fact that the contracted entity is responsible for maintaining the record of the client's cash balance through said settlement account, and not through the collective account that the entity maintains at the fiduciary bank.

What it means for you

If you are a natural person resident in Spain and hold interest-bearing accounts or any type of account in financial institutions located abroad, you must pay special attention to bank statements. It is common for different entity names or BIC codes that do not match your bank's name to appear in the transactions. An error in identifying the entity or the IBAN could lead to an incorrect declaration of your assets.

What you should do

In the presence of accounts where the contracted entity and the fiduciary bank are different, it is necessary to precisely identify the entity with which the contractual relationship is maintained. You must verify that the reported IBAN is that of the settlement account assigned to the holder and not that of the entity's collective account. Given the complexity of these banking structures, it is necessary to assess each particular situation to ensure that the declared information is accurate.