Spain's tax authorities have confirmed that cryptocurrency held in self-custody wallets does not have to be included in Form 721, provided the taxpayer controls the private keys and no foreign third-party custodian safeguards the assets. The treatment applies to both hot and cold wallets because custody and control, rather than internet connectivity or wallet type, determine the reporting obligation. Form 721 covers qualifying virtual currencies held abroad through custodians and applies when the relevant holdings exceed €50,000. Spain's Directorate General of Taxes set out the position in binding consultation V0848 26, issued April 21, involving a Spanish resident's foreign company and crypto holdings. Self-custody remains subject to other reporting systems: under DAC8, regulated crypto service providers can record transactions involving transfers between their platforms and external, self-custodied addresses. Taxpayers who held qualifying custodial assets during the year may also have reporting duties even if ownership or disposal rights ended before Dec. 31.