The March 31 deadline for filing informative Forms 720 (foreign assets and rights) and 721 (crypto assets held outside Spain) is approaching. However, beyond the formal compliance with an information obligation, what is truly relevant is the current context in which these filings take place.
Over recent years, the international tax system has changed significantly. Today, tax authorities worldwide automatically exchange large volumes of financial and asset information through mechanisms such as CRS, FATCA, the various EU DAC directives, and new crypto-asset reporting systems. This means that the Spanish Tax Agency systematically receives data directly from foreign banks, digital platforms, financial service providers, and other tax administrations.
But the change is not only quantitative; it is also qualitative. The AEAT has significantly increased and will continue to increase its ability to analyse and exploit this information through advanced analytics tools and artificial intelligence systems. Data is no longer analysed in isolation, but as complete patterns: asset evolution, consistency between declared income and assets held abroad, cross-border financial movements, or discrepancies between different sources of information.
In practice, this results in a higher number of informational notices, requests, and audits when inconsistencies or non-compliance are detected. It is expected that these actions will increase as the Tax Agency further enhances its analytical capabilities through artificial intelligence. Foreign assets are no longer invisible, and the trend clearly points towards a progressive increase in monitoring and detection capacity.
For this reason, it is particularly important to review in advance whether there is an obligation to file Forms 720 or 721 when holding bank accounts, investments, real estate, or crypto assets outside Spain. More than ever, prevention and proper review of information obligations have become key elements in avoiding future tax risks.
At addwill, we have a specialised International Tax team advising clients with assets abroad. If you hold assets or investments outside Spain, now is a good time to review your situation before the filing deadline for the informative returns on March 31.