The South African Revenue Service (SARS) has announced its participation in a collective international engagement to support the development of a framework for the automatic exchange of readily available information on immovable property. This initiative represents a significant next step in the global tax transparency agenda and signals a growing focus by tax authorities on asset classes that have historically fallen outside automated information-exchange regimes.
While the framework is still in development and will be implemented over the medium term, the direction of travel is clear: cross-border ownership of immovable property is moving firmly into the scope of international tax transparency.
Context: Closing a Long-Standing Transparency Gap
Over the past decade, international tax cooperation has expanded rapidly. The introduction of automatic exchange of financial account information, followed by enhanced reporting for crypto-assets, has substantially reduced the ability of taxpayers to hold offshore financial assets outside the visibility of tax authorities.
Immovable property, however, has remained a notable exception. Despite often representing a substantial store of wealth and a source of taxable income, foreign property ownership has generally relied on self-reporting, supported only by limited and fragmented information sharing between jurisdictions.
The proposed framework for the automatic exchange of readily available information on immovable property is intended to address this structural gap by enabling tax administrations to obtain consistent and reliable data on property held by non-residents in their jurisdictions.
SARS’ Position and International Alignment
SARS has aligned itself with a growing group of jurisdictions that recognise the importance of enhanced cooperation in this area. The collective engagement reflects a shared commitment to strengthening tax compliance, improving risk assessment, and promoting fairness within domestic tax systems.
Importantly, SARS has indicated that participation in the multilateral agreement will be subject to domestic processes and timelines, with implementation anticipated later in the decade. This measured approach reflects the practical realities of legislative change, systems development, and inter-governmental coordination.
What “Readily Available Information” Is Likely to Mean
Although the detailed scope of information to be exchanged has not yet been finalised, the concept of “readily available information” suggests a focus on data already held by public authorities. This may include:
- Property ownership and registration details
- Information on transfers of immovable property
- Certain valuation or transactional data available through land registries or similar bodies
The framework is not expected to require the creation of entirely new data sets in the early stages but rather the structured exchange of information that tax authorities already collect for administrative purposes.
Implications for Taxpayers and Advisors
From a practical perspective, this development reinforces a broader trend: foreign immovable property should no longer be viewed as a low-visibility asset from a tax perspective.
For South African taxpayers with offshore property interests, the increased availability of third-party data heightens the importance of ensuring that ownership, income, and gains are correctly disclosed and aligned with exchange-control, income tax, and capital gains tax requirements.
For advisors, the initiative underscores the need to factor information-exchange risk into cross-border structuring, estate planning, and property investment advice. Assumptions that enforcement relies primarily on voluntary disclosure are becoming increasingly outdated.
Why This Matters for South Africa
SARS’s participation in this initiative is consistent with its broader shift towards data-driven compliance and enhanced international cooperation. As fiscal pressures increase and tax authorities globally seek to protect their revenue bases, access to better information, rather than higher tax rates, is increasingly the preferred enforcement tool.
For South Africa, improved visibility over offshore property holdings supports both revenue collection and the integrity of the tax system. It also places South African taxpayers on a more level footing with their global peers as transparency standards continue to converge.
Looking Ahead
While the automatic exchange of immovable property information will not take effect immediately, the strategic message is unambiguous. The global transparency framework is expanding beyond financial assets, and immovable property is firmly in scope.
Taxpayers with international property interests would be well advised to treat this development as an opportunity to review existing structures, disclosures, and compliance positions, before enhanced information flows make those reviews unavoidable.
The move towards automatic exchange of immovable property information marks a decisive shift in global tax transparency. Offshore property is no longer “invisible”, and South African taxpayers with international property interests should ensure their structures, disclosures and compliance positions are robust and up to date.
If you need support assessing your exposure, reviewing your offshore property structures, or navigating the cross-border tax implications, our team at Regan van Rooy is well placed to assist.
Get in touch with us for tailored advice and ensure your affairs remain compliant, defensible and strategically positioned in this evolving transparency environment.
English 
French