Doctrine by topic · DGT Observatory

Credit Institutions: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Stable position Low confidence 9 rulings · 2015–2025

Current position

Credit institutions must report annually on accounts and their balances using Form 196, with a filing period between January 1 and January 31 of the following year. Likewise, they must comply with individualized information requests made by the Tax Administration. In the case of abandoned cash balances and deposits, these must be reported and transferred to the Treasury.

The DGT's position does not show a single doctrinal evolution, as the rulings address heterogeneous matters such as billing exemptions, collection, the calculation of the tax base, or the management of abandoned balances. There is no change in criterion regarding a central concept, but rather a dispersion of regulatory applications depending on the specific case.

Turning points

  1. V0651-24

    Establishes that abandoned cash balances and deposits must be reported and transferred to the Treasury as they constitute an exception to the prohibitions under tax regulations.

Analysis based on 9 of 9 rulings with a stated position. Updated 30 September 2026.

Rulings on this topic

9
V3119-19 7 Nov 2019

Obligation to file the informative return on foreign accounts

SG de Tributos
declaración informativamodelo 720titular realextinción de cuentasentidades de crédito LGT — Ley 58/2003 General Tributaria art. 29LGT — Ley 58/2003 General Tributaria art. 89.1
Affects CompanyExpat · Non-residentIndividual
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