Crypto: 720, 721 or Renta?
Clear map: accounts and securities go on 720, crypto custodied abroad on 721, capital gains on Spanish income tax.
The ideas in this guide are there to explain what belongs on Modelo 720, what on 721 and what on Renta. With Aitax you upload the documents: the AI takes care of the heavy lifting. You check that the figures are right. If a question comes up, you ask the specialised AI, trained on the law as it stands.
If you hold Bitcoin on an exchange, stocks at DeGiro and a flat in Lisbon, they do not go on the same Spanish form. Hacienda splits three jobs: traditional foreign assets (720), crypto custodied abroad (721), and capital gains on the income tax return (Renta / Modelo 100).
Short answer: foreign accounts, securities and property → Modelo 720. Crypto at a non-Spanish custodian, if you exceed €50,000 on 31 December → Modelo 721. Gains or losses when you sell crypto or shares → Renta. The 721 does not assess tax; the Renta does.
Product: Aitax prepares Modelo 721 (read-only API or CSV). Modelo 720 is built from broker statements. Gains go on Renta.
The map: three boxes, not one
| What you hold | Where it is reported | Tax paid on that form? |
|---|---|---|
| Foreign account, stocks, funds, property | Modelo 720 (if thresholds are met) | No. Informative |
| Crypto at a foreign exchange (third-party custody, non-resident) | Modelo 721 (if ≥ €50,000 at 31 Dec) | No. Informative |
| Sales of stocks, funds or crypto; dividends | Renta / Modelo 100 | Yes. Gains and income |
Informing is not the same as paying tax. Filing 721 does not “cover” crypto gains. Filing 720 does not replace Renta boxes.
Modelo 720: accounts, securities, property
Form 720 reports assets and rights located abroad: bank accounts, securities, insurance and real estate. The usual threshold is €50,000 per block (accounts / securities / property). The filing window is typically 1 January to 31 March.
Cryptocurrency does not go here. Putting BTC on a 720 is the mismatch Hacienda can cross-check against 721 data.
If you use DeGiro, Interactive Brokers, Revolut or XTB, the 720 asks for identifiers and valuations that are not sitting neatly on the PDF. Aitax for 720 reads those statements; it does not ask you to build a spreadsheet first.
Modelo 721: crypto custodied abroad
Form 721 is the informative return for virtual currencies located abroad. In practice: balances at exchanges or custodians not resident in Spain, valued at 31 December.
You must file if the combined value exceeds €50,000 on that date. In later years, if the increase exceeds €20,000 versus the last return filed (or you close/transfer relevant balances). The deadline matches the 720: 31 March.
Usually out of 721:
- A cold wallet (Ledger, Trezor) where you hold the keys: no foreign custodian. Legal debate exists; the 721 duty focuses on third-party custody abroad.
- An exchange resident in Spain: they report to Hacienda. You typically do not file 721 for those balances. Sales still go on Renta.
Example: €42,000 on Binance and €12,000 in a Portuguese bank. The bank may trigger 720. Binance, if total crypto is under €50,000, does not trigger 721. The €42,000 is not added to the 720 bank block to “help” you reach the threshold.
Renta: where crypto gains are taxed
Every sale, swap or spend of crypto is an income-tax event (capital gain or loss), with its own rules (FIFO, valuation, fees). That is not declared on 721. 721 is a year-end snapshot; Renta is the year’s film.
If you also hold the same ISIN at two brokers, Renta FIFO is across homogeneous accounts (art. 37.2 LIRPF), not “DeGiro’s FIFO” plus “IBKR’s FIFO”.
Aitax Renta is built for investors with statements, not for pasting a payroll certificate.
Example in euros
Marta, Spanish tax resident, at 31 December:
- €80,000 in IBKR stocks (Ireland)
- €55,000 in BTC and ETH at a foreign exchange
- During the year she sold ETH with a €4,200 gain
What she files:
- Modelo 720 for the securities (over €50,000 in that block).
- Modelo 721 for the crypto (over €50,000).
- Renta: the €4,200 ETH gain (and whatever the stocks require).
If the exchange “does the 721 for her”, she still owes those gains on Renta. If she only files Renta and skips 721, many exchanges already send data: the information gap is what opens a notice.
The right Aitax product
- Crypto at a foreign exchange → Modelo 721: read-only API or CSV; 31-Dec balances; XML for Hacienda.
- Brokers and foreign property → Modelo 720: statements as-is, Q4 averages, ECB rates.
- Stock or crypto gains → Renta.
Do not use a payroll tax app to rebuild IBKR FIFO, or a 720 script for 721 XML.
FAQ
I have €40,000 in a foreign bank and €20,000 in crypto. Must I file?
Not on those amounts. The €50,000 thresholds are separate. You meet neither 720 nor 721. Sales during the year still go on Renta.
Does 721 replace crypto on Renta?
No. Informative ≠ tax due.
Does a Spanish exchange remove 721?
For balances custodied in Spain, usually yes (they report). Sales still go on Renta.
Cold wallet?
721 targets third-party custody abroad. Keep records: selling still hits Renta.
Crypto on a foreign exchange?
Connect the exchange and leave Modelo 721 ready for Hacienda.
Related guides
Back to guides- Do I need to file Modelo 721?A 10-second tree: foreign exchange, €50,000 at 31 Dec, cold wallet, and Spanish-resident exchanges.
- Modelo 720 threshold: from what amount must you file?When Modelo 720 applies (~€50,000 per block), what counts as foreign assets, and what goes on Modelo 721.
- Modelo 720 guide: who must file and the deadlineLearn everything about Modelo 720: who must file, deadlines, and how to avoid fines.