加强房地产国际税收透明度——从概念到现实：经合组织向G20财长和央行行长提交的报告

Strengthening International TaxTransparency on Real Estate–FromConcept to RealityOECD Report to G20 Finance Ministers and Central BankGovernors PUBE STRENGTHENING TAXTRANSPARENCY ON REAL ESTATE © OECD 2024This work is published under theresponsibility of the Secretary-General of the OECD. The opinionsexpressed andarguments employed herein do not necessarily reflect the official views of the Membercountries of the OECD.This document, as well as any data and map included herein, are without prejudice to the status of orsovereignty over any territory, to the delimitation of international frontiers and boundaries and to the nameof any territory, city or area.Please cite this report as:OECD (2024),StrengtheningInternational Tax Transparency on Real Estate–From Concept to Reality:OECDReport to G20Finance Ministers and Central Bank Governors, OECD Publishing, Paris,https://doi.org/10.1787/fa2db2a4-en.Attribution4.0 International (CCBY4.0)This work is made available under the Creative Commons Attribution4.0 International licence. By using this work, you accept to be bound by the terms of this licence (https://creativecommons.org/licenses/by/4.0/).Attribution–you must cite the work.Translations–you must cite the original work, identify changes to the original and add the following text:Inthe event of any discrepancy between the original work and the translation, only the text of originalwork should be considered valid.Adaptations–you must cite the original work and add the following text:This is an adaptation of an original work by the OECD. The opinions expressed and arguments employed in this adaptation should notbe reported as representing the official viewsof the OECD or of its Member countries.Third-party material–the licence does not apply to third-party material in the work. If using such material, you are responsible for obtaining permission from the third party and for any claims of infringement.You must not use the OECD logo, visual identity or cover image without express permission or suggest the OECD endorses your useof the work.Any dispute arising under this licence shall be settled by arbitration in accordance with the Permanent Court of Arbitration(PCA) Arbitration Rules2012. The seat of arbitration shall be Paris (France). The numberof arbitrators shall be one. STRENGTHENING TAX TRANSPARENCY ON REAL ESTATE © OECD 2024ForewordBuilding on the July 2023 Report to the Indian G20Presidency, this reportlooks into current levelsof taxtransparency on foreign owned real estate and explores how recentadvancesin other tax transparencyframeworks, such as the Common Reporting Standard(CRS),and widerpolicydevelopments, such astheFinancial Action Task Force (FATF)’s workon beneficial ownership,could inform improvements to taxtransparency in the area of real estate.The report identifies potentialshort-term and structural improvements to the present architecture toenhance tax transparency with respect to real estate, along three key milestones.Firstly, the report proposes building blocks to ensure the efficient exchange of readily available informationon real estate transactions, holdings and income between tax administrationsto allowinterested countriesand in particularthe close to 150jurisdictions participating in the Multilateral Convention on MutualAdministrative Assistance in Tax Matters(MAAC)to fully benefit from the existing exchange network.Secondly, the report sets out an approach for further enhancing the consistency and quality of theinformation through common due diligence and reporting requirements for real estate-relatedexchanges.Finally, the report presents key considerations for a potential structural model for ensuring the taxtransparency on real estate, including where held indirectly through legal entities and arrangements, onthe basis of fast-track accessfor tax purposesto information in real estate and beneficial ownershipregisters. STRENGTHENING TAXTRANSPARENCY ON REAL ESTATE © OECD 2024Table of contentsForewordExecutive summaryBuilding blocks for strengthening tax transparency on real estate1. Regular exchange of readily available information2. Enhancing the consistency and quality of the information3. Ensuring the availability of up-to-date beneficial ownership information on real estateFIGURESFigure 1. Sources of the information on transactions and holdings of real estateFigure 2. Sources of the information on recurrent income derived from real estateFigure 3. Priority level regarding the intended use of information per type of real estate of informationFigure 4. Legal instruments relied upon for exchanges ofreal estate informationFigure 5. Categories of real estate information being exchangedFigure 6. AEOI on the basis of common reporting and due diligence rules 357716188910131317 STRENGTHENING TAX TRANSPARENCY ON REAL ESTATE © OECD 2024ExecutivesummaryIn response to a request by last year’s IndianG20Presidency, the OECD prepared a report for theJuly2023meeting of the G20Finance Minist