In recent years, international tax transparency has undergone a profound transformation. After the implementation of the Common Reporting Standard (CRS) and the automatic exchange of financial account information, global attention is now shifting to foreign real estate holdings. This asset class historically remained outside the scope of automatic reporting. In its latest reports to the G20, the OECD has outlined a new framework aimed at significantly expanding transparency obligations, thereby reshaping how foreign property ownership is monitored and shared among tax authorities. If adopted, these reforms would represent a significant step forward in the global effort to combat tax evasion and asset concealment.
A Turning Point for Real Estate Transparency
The OECD proposal introduces a three-pillar system aimed at improving data availability, comparability, and accessibility across jurisdictions:
- Automatic Exchange of Information on Foreign Real Estate
Tax authorities would receive structured, periodic data on properties owned abroad by their tax residents, effectively closing a major gap in the reporting framework. - Standardised Data Collection and Quality Requirements
Harmonised standards for property data would enable tax administrations to cross-check information more efficiently and support targeted audits. - Access to Beneficial Ownership Information
Authorities would gain direct visibility over the underlying individuals behind property-holding structures such as companies, trusts, or foundations, reducing the opportunities for asset concealment.
Why This Development Matters
Owning property abroad has often implied limited disclosure, as real estate reporting was not part of the automatic exchange regime. Under this new framework, such privacy is likely to disappear. The increased availability of structured information allows tax authorities to:
- Identify undeclared real estate held abroad
- Perform cross-border audits and data-matching
- Detect discrepancies between declared income, wealth, and property assets
Consequently, the risk of retroactive tax assessments, penalties, and requests for voluntary regularisation is expected to rise, particularly for individuals who did not properly report their foreign assets.
Who Will Be Affected?
Although the final scope is still under negotiation, the framework is expected to impact:
- Individuals owning real estate outside their country of tax residence
- Properties acquired via companies, trusts, or corporate arrangements
- High-net-worth individuals and families with cross-border wealth planning strategies
With the ongoing digitalisation of land registers and enhanced international cooperation, the detection of irregularities will become significantly more efficient.
Interaction with Existing Transparency Frameworks
This initiative builds directly on existing global tax transparency mechanisms such as CRS, FATCA, and Ultimate Beneficial Owner (UBO) registers. While CRS currently covers only financial accounts, this extension to real estate aims to create a comprehensive international framework for both financial and non-financial assets.
For trustees, family offices, and wealth advisers, this represents a turning point:
- There is now a clear need to review all real estate holding structures
- Reporting obligations across jurisdictions must be reassessed
- Early proactive compliance aligns best with emerging regulatory standards
Conclusion
The OECD’s proposal signals a new era for international tax transparency. If implemented, it will extend automatic reporting from financial accounts to real estate, fundamentally reshaping wealth planning and compliance for individuals with cross-border property. In this evolving environment, prompt regularisation and effective tax planning are critical. Ensuring compliance today will safeguard wealth and protect long-term interests. Ebco Group is committed to supporting clients in navigating these changes through tailored guidance, risk assessment, and regularisation strategies.
Sources
- OECD, “Enhancing International Tax Transparency on Real Estate,” July 2023.
- OECD, “Strengthening International Tax Transparency on Real Estate: From Concept to Reality,” July 2024.
- Rosemont International, “OECD’s 2025 Real Estate Transparency Framework: What It Means for Cross-Border Property Owners,” Oct 2025.
- ECNews, “Immobili siti all’estero detenuti da entità fiscalmente trasparenti,” luglio 2025.
