The €50,000 limit in Form 720 applies to independent asset blocks

The Directorate General of Taxation (DGT) has issued a relevant ruling regarding the application of quantitative thresholds in Form 720, the informative declaration of assets and rights located abroad. The doubt lay in whether the €50,000 limit should be considered globally or if it applied in a segmented manner according to the type of asset.

What the DGT has resolved

The body has determined that the €50,000 limit applies independently to each of the three asset blocks regulated in the Wealth and Large Fortunes Tax Regulation (RGAT). These blocks are:

• Accounts in financial institutions.
• Securities, rights, and financial institutions.
• Real estate, rights over real estate, and other assets.

According to the resolution, each block constitutes a distinct reporting obligation, even though all are declared in the same form. Therefore, if the value of the assets in one of these blocks exceeds the €50,000 threshold, the taxpayer is obliged to report all the elements that make up said block.

What this means for you

This ruling has a direct impact on tax residents in Spain who hold assets abroad. It means that the sum of all assets abroad does not need to exceed €50,000 to trigger the obligation to declare. If, for example, a taxpayer owns real estate abroad valued at €60,000, but their foreign bank accounts only total €10,000, they must report all the real estate, even though they do not need to report the accounts.

What you should do

It is essential to perform a detailed analysis of the composition of assets located outside of Spain. Since the reporting obligation is activated independently for each block, it is necessary to verify the value of each category separately to determine if the legal limit has been reached. It is recommended to assess each wealth situation individually to ensure compliance with reporting obligations according to the RGAT and the General Tax Law.