It widens the scope of global tax transparency to immovable property, an asset class that had remained outside automatic exchange mechanisms such as the Common Reporting Standard (CRS). According to the OECD’s Tax Transparency in Asia Report 2025, member jurisdictions identified at least 24 billion in additional revenue between 2009 and 2024 through exchange-of-information mechanisms. In 2024 alone, 1.9 billion was identified.
India, during its G20 presidency, had been a votary of widening the scope of the CRS to include non-financial assets such as real estate under automatic exchange among the 38-member OECD. The push led to a dedicated multilateral framework for the automatic exchange of immovable property information.
The framework has significant implications for Indian residents holding property abroad through companies, trusts or special purpose vehicles (SPVs). It alters how overseas property structures will be viewed by tax authorities, said Rishabh Shroff, partner and co-head (private client) at Cyril Amarchand Mangaldas.
“The OECD’s property-exchange framework is a decisive shift for globally mobile Indian families. Structures that once kept overseas real estate insulated—SPVs, layered trusts, property-linked residency routes—will now sit under direct, automatic scrutiny,” he said, adding that India’s residency-based tax system and reporting rules under the Foreign Exchange Management Act heighten the impact.
Tightening of property-led residency regimes abroad had already prompted wealthy families to shift away from traditional real estate-linked pathways, according to Shroff. “With Europe tightening property-led visas and extending golden visa timelines, Indian HNIs are pivoting towards business, fund and donation-driven residency options that offer substance without the disclosure fragility of ‘pure’ direct real estate acquisition,” he said.
The changes are also influencing investment-linked migration decisions.“Property-led Golden Visa investors depend heavily on real estate investment for residency eligibility. Automatic exchange means every detail—acquisition price, financing, rental income, beneficial ownership—will be shared with Indian authorities,” said Rajneesh Pathak, founder of Global North Residency & Citizenship.
“Many clients who used property as a ‘quiet’ asset diversification tool are re-evaluating,” Pathak said, adding that clients are responding by improving documentation and reporting.
“We are also seeing clients proactively organising clean source-of-funds documentation, rental income reporting, financing trails and OECD-aligned valuations.”
For families with complex holding structures, compliance risks are higher, said Gopal Kumar, founder of borderless.VIP. “Challenges arise when either the source of funds or the property itself has not been properly declared,” he said, adding that layered SPVs and multi-jurisdictional ownership structures would face greater scrutiny as beneficial ownership and income details become visible.
The areas most impacted are residency and citizenship programmes built around real estate investments, such as those in parts of Southern Europe, the Caribbean and Southeast Asia, and any inconsistency will stand out quickly, according to Kumar.
The framework closes a long-standing gap, said Keshav Singhania, head, private client, at Singhania & Co. “Offshore companies, trusts and nominee structures holding real estate have historically remained outside automatic reporting,” he said, noting that while timelines are defined, exchanges will materialise gradually as bilateral arrangements take effect.
ET Bureau
