In December 2025, twenty-six jurisdictions made a political commitment to adhere to a new multilateral framework for the automatic exchange of information on immovable property held abroad. The initiative, promoted by the Organisation for Economic Co-operation and Development (OECD), seeks to address a gap in the architecture of international tax cooperation: the absence of a standardized mechanism for the systematic sharing of data relating to non-financial real estate assets.
In recent years, international transparency has evolved significantly with respect to financial and digital assets. The real estate sector, however, has remained characterised by uneven levels of information exchange, often limited to specific requests. At the same time, the increase in cross-border real estate investment has increased the risks of under-reporting of assets and income by taxpayers resident in other jurisdictions. The new Framework for the Automatic Exchange of Readily Available Information on Immovable Property for Tax Purposes, presented to the G20 in October 2025, aims to address this issue.
The proposed model is based on a multilateral agreement between competent authorities that allows for the automatic exchange of 'readily available' information on immovable property. This is data already held in electronic format by tax administrations or public registers – such as land registers or beneficial ownership registers – and considered sufficiently reliable and up to date to be shared. A pragmatic approach has been adopted: the framework seeks to leverage existing information without, at this stage, introducing additional or generalized reporting obligations for market operators or intermediaries, such as notaries or real estate agents.
The agreement is structured around two modules, which jurisdictions may adopt with a degree of flexibility: one designed to provide visibility on properties held abroad by their residents, and another focusing on income and capital gains derived from such properties. The first module provides for an initial exchange of information on immovable property already held at the time the bilateral relationship becomes operational, followed by annual exchanges relating to newly acquired properties. The second module entails an annual exchange of information concerning disposals of property and recurring income streams, such as rental income.
In summary, the information to be exchanged includes:
The exchange of information is carried out under the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. In practice, each jurisdiction must specify which data it is able to transmit, with which partner jurisdictions it intends to activate exchanges, and for which taxes the information may be used. The first exchange relating to property already held must take place by 31 January of the year following the entry into force of the agreement between the two competent authorities. Subsequent annual exchanges must be completed by the same date and, in any event, no later than 30 June of the relevant year.
The joint declaration of 4 December 2025 indicates the signatories' intention to formally adhere to the agreement by 2029 or 2030, subject to their respective domestic procedures.
The jurisdictions involved include Belgium, Brazil, Chile, Korea, Costa Rica, Finland, France, Germany, Gibraltar, Greece, Indonesia, Ireland, Iceland, Indonesia, Ireland, Italy, Lithuania, Malta, Norway, New Zealand, Peru, Portugal, the United Kingdom, Romania, Slovenia, Spain, South Africa and Sweden.
The initiative remains open to further participation and represents a further step in strengthening administrative cooperation to categories of assets that have so far been less regulated at the multilateral level. For tax administrations, the new system will provide a more structured information base for verifying the correct declaration of assets and real estate income held abroad. For taxpayers and participants in the international real estate market, the framework confirms an already well-established trend: the growing integration of information flows between jurisdictions is progressively reducing areas of opacity, including in relation to non-financial assets.
This article is by Adela Muniz, This article is edited by Adela Muniz, Head of the Family Office Competence Center by Fidinam & Partners.
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