New Framework for the Exchange of Real Estate Information for Tax Purposes

A Significant Step Toward Global Tax Transparency: Tax Authorities from 25 OECD Countries to Exchange Real Estate Information

ֿTwenty-five countries have agreed to join a new OECD initiative for the automatic exchange of real estate information between tax authorities. This international initiative aims to reduce tax evasion and enhance transparency in the real estate sector, which is considered one of the primary channels for cross-border investments.

Countries that signed the joint declaration include the United Kingdom, Brazil, Costa Rica, France, Germany, Ireland, Italy, and Spain. The countries stated their intention to join the framework by 2029 or 2030, subject to completion of domestic legislative procedures in each jurisdiction.

The New Framework: Automatic Exchange of Real Estate Information

In October 2025, the OECD published the framework for automatic exchange of real estate information for tax purposes.

The framework provides a structure for countries to automatically and regularly exchange real estate information. It ensures compliance with uniform legal and technical standards. Its goal is to address a growing global challenge – tax avoidance in real estate transactions. Transactions and ownership of real estate assets often involve cross-border elements. This makes it difficult for tax authorities to track derived income. Accordingly, a robust mechanism is required to provide tax authorities with access to information about their resident’s real estate holdings abroad. This enables effective enforcement of tax obligations.

For instance, a French resident living in Paris purchased an apartment in Berlin and rents it. The rental income is taxable in France as the country of residence. It is also taxable in Germany where the income was generated. Absent an automatic exchange mechanism, the French Tax Authority might remain unaware of the property. The owner may fail to report the income. Under the new agreement, Germany will automatically transfer information to France regarding property ownership and derived income. This will facilitate effective enforcement of tax obligations.

The joint declaration stated that this initiative “will enhance our ability to monitor and enforce tax compliance and to combat tax evasion, which undermines public revenues and unfairly shifts the tax burden onto compliant taxpayers.”

Part of a Broader Global Information Exchange System

The new framework joins two previous OECD initiatives for automatic information exchange:

Common Reporting Standard (CRS), developed in 2014, created a mechanism for exchanging information on financial assets held in traditional financial institutions.

Crypto-Asset Reporting Framework (CARF), under which up to 75 countries are expected to begin sharing information on digital asset transactions, starting in 2027 or 2028.

With the adoption of the new real estate framework, an integrated global system has been created. It combines three domains of information exchange: financial, digital, and real estate.

Implications for Investors and Taxpayers

The new framework will affect investors holding real estate assets in participating countries. Automatic information exchange will enable tax authorities in different countries to receive data on real estate assets. This includes ownership details, transactions, and income from properties owned by foreign residents.

This measure is not expected to affect taxpayers who duly comply with reporting obligations. In contrast, taxpayers who have not reported real estate assets or foreign income to date will face greater difficulty. It will be significantly harder to continue evading reporting obligations when information is transferred automatically between tax authorities. In this context, some countries have procedures for settling tax liabilities for previously unreported income.

Recently (August 25, 2025), the Israel Tax Authority published a Voluntary Disclosure Procedure. The procedure provides an opportunity for taxpayers who have not reported their income over the years to settle the reporting and tax liability. This includes interest and indexation differentials accruing from the end of each unreported year until the tax payment date. Taxpayers receive criminal immunity from prosecution. The voluntary disclosure request must be submitted with a brief background and calculations to the Investigations Division of the Israel Tax Authority. Upon receipt of the request, the Investigations Division reviews the taxpayer’s background. It verifies whether the case is under audit, whether an overt or covert investigation is being conducted against the taxpayer, and whether there is any reason not to approve the voluntary disclosure. After the examination, if all findings are satisfactory, the taxpayer receives approval to begin the voluntary disclosure process and to obtain criminal immunity.

This year, our firm published the entry on voluntary disclosure on Wikipedia. To view the entry, click here.

For additional information on voluntary disclosure procedures regarding:

• Settlement of capital gains
• Crypto assets
• Foreign accounts
• Non-reporting of rental income
• Criminal immunity and protection from prosecution

The expected participation of 25 countries in the OECD’s new framework by 2030 represents a significant step toward broader tax transparency in the real estate sector. For investors and international property owners, this is a major development. It requires a fresh review of reporting obligations and compliance requirements.

Real estate owners with foreign holdings are advised to review their tax position. They should ensure compliance with existing reporting requirements. Nimrod Yaron & Co. specializes in consulting and handling matters of international assets, voluntary disclosure, and adapting tax structures to the changing regulatory environment. Contact us for professional and personalized advice.

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