Real estate and automatic exchange of information: the end of property opacity

For a long time, real estate has remained one of the last areas of relative opacity in international tax matters. While bank accounts and financial assets have been subject to increasing levels of automatic exchange, immovable property largely escaped systematic cross-border visibility.

That era is coming to an end.

With the publication of the OECD’s Framework for the automatic exchange of readily available information on immovable property, real estate is now firmly on the path toward the same level of transparency that reshaped financial compliance over the past decade.

The OECD framework: what has just been published

The OECD framework sets out a model that jurisdictions may adopt to automatically exchange information relating to immovable property held by non-residents.

It is important to be precise: this is not, at this stage, a binding obligation. It is a detailed and operational framework designed to be implemented by willing jurisdictions, much like the Common Reporting Standard was at its inception.

The objective is clear. To enable tax authorities to obtain, on a regular and systematic basis, reliable information on foreign-owned real estate assets that are currently difficult to monitor across borders.

A modular approach to real estate transparency

The framework is structured around two complementary modules.

Together, they are designed to provide tax authorities with a comprehensive view of:

• ownership and beneficial ownership of immovable property,
• acquisition and disposal events,
• and recurring income derived from real estate.

This modular design allows jurisdictions to progressively expand the scope of exchanged information while relying on data that is already available at the domestic level.

Why this goes far beyond the CRS

The Common Reporting Standard fundamentally changed the landscape for financial assets. But it never fully addressed real estate.

Immovable property is not held in accounts. It is registered locally, often through land registries or notarial systems that are not connected to international exchange mechanisms.

The OECD framework fills that gap.

Once implemented, it will allow tax authorities to:

• identify foreign owners of domestic real estate,
• link property ownership to beneficial owners,
• monitor rental income streams,
• and cross-check declared positions with actual ownership and transactions.

In practical terms, this removes a long-standing blind spot.

What information will become visible

Under the framework, the information potentially subject to exchange includes:

• the identity of the legal owner and the beneficial owner,
• the location and characteristics of the property,
• acquisition and disposal dates and values,
• and income generated from the property, where available.

For international property owners, this means that real estate assets will no longer sit outside the scope of global transparency mechanisms.

France’s position: more than a passive observer

In March 2025, the French government publicly confirmed its support for extending automatic exchange of information to cover real estate assets and income, including beneficial ownership transparency.

This statement is not incidental.

France has been among the most active jurisdictions in promoting tax transparency initiatives at the OECD level. Its support sends a clear political signal: once the framework is available, France is likely to be among the jurisdictions pushing for rapid adoption.

For owners of French real estate held through foreign structures, this matters.

What this means for international real estate owners

The shift toward automatic exchange fundamentally changes the risk profile of cross-border real estate ownership.

Structures that relied on passive opacity — not concealment, but simple lack of visibility — will be reassessed under a new lens. Information that was previously fragmented across registries and jurisdictions will become consolidated and accessible.

This is likely to trigger:

• targeted tax audits,
• re-examination of historic filings,
• and increased scrutiny of structures that lack economic or legal substance.

Timing matters more than ever

There is a critical distinction between anticipation and reaction.

While the framework is not yet universally implemented, the direction is set. Experience with previous transparency initiatives shows that once the infrastructure is in place, adoption tends to accelerate.

This creates a narrowing window during which restructuring, clarification and alignment can still be carried out calmly, rather than under the pressure of an investigation.

Conclusion: a checklist before real estate becomes fully transparent

Before assuming that real estate holdings will remain discreet by default, it is worth reassessing existing structures against a few key questions.

A practical checklist for international real estate owners

You should be able to answer “yes” to each of the following:

• Do you have a clear view of how your real estate assets are reported in each relevant jurisdiction?
• Is the ownership and beneficial ownership of your properties consistent with your tax filings?
• Are acquisition, disposal and income flows properly documented and aligned across borders?
• Would your structures withstand a cross-check once property data is automatically exchanged?
• Have you anticipated how increased transparency may affect your overall tax position?

If one or more of these questions raises hesitation, the issue is rarely theoretical. It is structural.

How we can help

At Altara Tax, we assist international entrepreneurs and high-net-worth individuals in reviewing and securing cross-border real estate structures in an environment of increasing transparency.

Our work focuses on:

• anticipating the impact of automatic exchange mechanisms,
• aligning ownership, substance and reporting positions,
• and restructuring proactively where existing arrangements are no longer robust.

When transparency becomes automatic, discretion is no longer a strategy.

Preparation is.