For private clients, family offices and cross-border investors, the shift is substantial. Real-estate has long been treated differently from financial assets, with most automatic-exchange regimes not covering property ownership, rental income, or sales proceeds. The IPI MCAA closes this gap by enabling jurisdictions to exchange information already held in land registries, tax files, beneficial-ownership registries and administrative databases.
How the framework works
The IPI MCAA is built around two reporting modules.
Module 1 covers property holdings and acquisitions. Participating jurisdictions will provide information on immovable-property owners, including individuals, companies, trusts, foundations and other structures. A one-off “look-back” will report on existing ownership, followed by annual reporting of new acquisitions and changes.
Module 2 covers income and disposals, notably rental income, sale proceeds and other taxable events. This information will also be exchanged automatically each year once jurisdictions activate the agreement.
Unlike CRS, the IPI MCAA generally does not impose new reporting duties on taxpayers or financial institutions. Instead, it relies on data already collected domestically and considered “readily available”, though the scope and quality of such data will vary across jurisdictions.
Which countries are involved
The initial signatories include several major economies: France, Germany, Malta, Italy, Spain, the UK, Ireland, Brazil, South Africa, Korea and others (see full list at the end of the article). More jurisdictions are expected to join as the framework becomes operational. Bilateral exchanges will begin once both jurisdictions have completed their domestic legal processes. The OECD anticipates that first exchanges could occur as early as 2029.
Implications for private clients and wealth-holding structures
For many families and investors, real estate is held through multi-layered structures, often using companies, trusts or foundations. Under the IPI MCAA, these arrangements may become far more transparent to foreign tax authorities, particularly where beneficial-owner information is available through registries or local AML frameworks.
Key impacts include:
• Exposure of offshore property holdings and historically undeclared rental income.
• Greater scrutiny of cross-border structures used for estate planning or asset protection.
• Increased compliance requirements for trustees, company directors and family offices.
• Potential alignment with other transparency regimes, including new beneficial-ownership standards and strengthened AML requirements.
Preparing for the new landscape
Clients and advisers should begin reviewing existing real-estate structures well before the framework becomes operational. Priority steps include mapping all cross-border property holdings, assessing where beneficial-owner information is already maintained, identifying potential disclosure risks and considering restructuring or regularisation where needed.
As with CRS, early preparation will be essential. The IPI MCAA represents a decisive move toward full transparency of global real-estate ownership, and families with international property portfolios will need proactive advice.
Rosemont International is available to assist with jurisdiction-by-jurisdiction impact reviews, structure assessments and compliance planning.
Read our article on new CRS reporting rules for 2026 here OECD CRS 2026: What financial institutions need to know about the new reporting rules
For more information, please contact consulting@rosemont.mc
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Committed Jurisdictions – IPI-MCAA (as of 4 December 2025)
| # | Jurisdiction | Region | Source Confirming Commitment |
| 1 | Belgium | Europe | German Ministry of Finance joint statement |
| 2 | Brazil | Latin America | OECD announcement |
| 3 | Chile | Latin America | International tax technical releases (Big 4) |
| 4 | Costa Rica | Latin America | International tax technical releases |
| 5 | Finland | Europe | German Ministry of Finance joint statement |
| 6 | France | Europe | OECD announcement |
| 7 | Germany | Europe | OECD + German Ministry of Finance |
| 8 | Greece | Europe | German Ministry of Finance joint statement |
| 9 | Iceland | Europe | International tax technical releases |
| 10 | Ireland | Europe | OECD announcement |
| 11 | Italy | Europe | OECD announcement + Ministry confirmation |
| 12 | Korea (Republic of Korea) | Asia | OECD announcement |
| 13 | Lithuania | Europe | International tax technical releases |
| 14 | Malta | Europe | German Ministry of Finance joint statement |
| 15 | New Zealand | Oceania | German Ministry of Finance joint statement |
| 16 | Norway | Europe | International tax technical releases |
| 17 | Peru | Latin America | International tax technical releases |
| 18 | Portugal | Europe | German Ministry of Finance joint statement |
| 19 | Romania | Europe | International tax technical releases |
| 20 | Slovenia | Europe | German Ministry of Finance joint statement |
| 21 | South Africa | Africa | OECD announcement |
| 22 | Spain | Europe | OECD announcement |
| 23 | Sweden | Europe | International tax technical releases |
| 24 | United Kingdom | Europe | OECD announcement + UK Treasury statement |
| 25 | Gibraltar (UK Overseas Territory) | Europe | German Ministry of Finance joint statement |
| 26 | Costa Rica / Iceland / Chile (completing the OECD’s count of 26)* | — | OECD: “26 jurisdictions committed” |