AUTHOR: GRAEME PALMER
DATE PUBLISHED: 20TH JANUARY 2026
South African tax residents are taxed on their worldwide income and capital gains. This may include income or capital gains received or accrued to them from properties owned by taxpayers in foreign jurisdictions. The South African Revenue Service’s (SARS) taxing rights in respect of such income and capital gains is subject to any tax treaty entered into with a foreign jurisdiction.
The Multilateral Competent Authority Agreement on the Automatic Exchange of Readily Available Information on Immovable Property (IPI MCAA) is an agreement for automatic sharing of searchable property data to help tax authorities spot foreign property and related income. SARS says it plans to join by 2029 – 2030.
The IPI MCAA lets countries exchange readily available, electronically searchable information about immovable property, such as who owns it, past acquisitions, disposals and income such as rent so that tax authorities can more quickly detect undeclared foreign property and income. Participating countries choose between two optional modules: one to capture property holdings and acquisitions (including a one‑off stocktake and then annual updates) and another to capture disposals and income on an annual basis.
Before joining, a tax authority must self‑assess what information it already holds that is “readily available” for exchange, which typically will include digital deeds or land registries, tax databases and beneficial‑ownership registers where accessible. The one‑off exchange should occur by 31 January of the year after the agreement takes effect between two jurisdictions, while annual exchanges should be completed by 31 January where possible and no later than 30 June, covering information from the prior year.
What this means for ordinary taxpayers is that foreign property and related income are more likely to be detected by SARS once exchanges begin, increasing the risk of audits, assessments and penalties for undeclared capital gains or income. For governments, the IPI MCAA is a practical step to close cross‑border tax gaps without bespoke information requests, but it depends on digital, searchable records and clear legal safeguards.
South Africans who generate income or capital gains from foreign properties should, as a starting point, check if there is a tax treaty between South Africa and the jurisdiction where their foreign property is situate. If there is a tax treaty determine which country has taxing rights in respect of the income and capital gains. If the foreign jurisdiction has taxing rights a tax return will need to be filed in that jurisdiction. A tax credit can be claimed in the taxpayer’s South African tax return for the tax paid in the foreign jurisdiction.
The countries that have indicated thus far that they will be participating in IPI MCAA are: Belgium, Brazil, Chile, Costa Rica, Finland, France, Germany, Greece, Iceland, Ireland, Italy, Korea, Lithuania, Malta, New Zealand, Norway, Peru, Portugal, Romania, Slovenia, South Africa, Spain, Sweden and the United Kingdom
In short, the IPI MCAA is a practical, standards‑based tool to improve tax transparency on property across borders; if SARS joins by 2029–2030, South African taxpayers with foreign property should expect stronger information flows and a greater need for accurate reporting and documentation.
Tel: +27 31 570 5496, Email graeme.palmer@gb.co.za