Executive summaryOn 27 January 2022, the Court of Justice of the European Union (CJEU) published a resolution (the Resolution) concerning the regulation of the obligation for Spanish tax residents to provide information with respect to overseas assets and rights (i.e., Form 720) and its penalty regime.The Resolution does not declare the obligation to provide information concerning assets and rights located abroad as contrary to European Union (EU) Law. However, the CJEU has ruled that the consequences established in the Spanish legislation for the failure to comply or the partial or late compliance with such obligation are disproportionate and limit the...