A New Path for Tax Transparency on Global Property

In 2023, an Indonesian crazy rich person purchased three luxury homes in Singapore’s Nassim Road area for a total of approximately Rp 2.3 trillion. As of mid-2026, the identity of this individual had not been revealed to the public. A crucial question then arises: have the tax authorities uncovered this asset ownership and what efforts have been made?

This question is increasingly relevant amid rising cross-border capital mobility and the prevalence of the shadow economy. Wealth is no longer solely stored in bank accounts protected by secrecy laws, but is spread across assets in various parts of the world. In this context, transparency regarding global property ownership is becoming a game changer in the international tax landscape.

Over the past two decades, Indonesia has participated in the era of transformation in international tax transparency. This commitment is realised through information exchange programmes for tax purposes, including Exchange of Information on Request (EOIR), Automatic Exchange of Information on Financial Account Information (AEOI) via the Common Reporting Standard (CRS), and the Crypto-Asset Reporting Framework (CARF).

This commitment was further strengthened by the issuance of Minister of Finance Regulation (PMK) Number 108 of 2025 concerning Access to Financial Information for Tax Purposes (AIK), which serves as the legal basis for implementing international financial information exchanges, including CRS and CARF. Through these implementations, the Directorate General of Taxes (DJP) can prudently and credibly receive and send cross-border financial and tax data with partner countries or jurisdictions.

The existence of CRS and CARF has changed the paradigm of global tax supervision. They emerged in response to the rapid development of financial and crypto assets worldwide. With these information exchange standards, previously inaccessible financial account and crypto asset data can now be utilised to test taxpayer compliance more effectively.

Currently, the development of international transparency has extended to the taxation of multinational corporations. Through the implementation of the Global Anti-Base Erosion (GloBE) Rules, part of the OECD’s Pillar Two, countries are preparing systems that enable more effective oversight of multinational enterprise groups. The annual GloBE Information Return and the exchange of information through the GIR will become a new database source for analysing compliance with minimum tax imposition in each country. These provisions are already covered in PMK Number 136 of 2024 concerning the Imposition of Global Minimum Tax Based on International Agreements. In the future, tax authorities will face high supervisory and law enforcement challenges over increasingly complex cross-border business activities.

The evolution of Exchange of Information (EOI) continues. Currently, the exchange of information on cross-border property ownership has not been definitively regulated by the OECD and DJP. Following the G20 South Africa meeting in 2025, the OECD developed a Framework for the Automatic Exchange of Readily Available Information on Immovable Property for Tax Purposes. This framework contains concise modules regarding the type of information, timeframes, and exchange schemes. To further strengthen implementation commitment, the OECD also released the Multilateral Competent Authority Agreement on the Exchange of Readily Available Information on Immovable Property (IPI MCAA) in December 2025.

If CRS, CARF, and GIR allow tax authorities to expand supervision over financial accounts, crypto assets, and multinational business group activities, the EOI-IPI will complete the tax transparency ecosystem by providing access to tangible assets of fantastic value that have been difficult to reach. Through this, participating countries can exchange information on property ownership, transaction values, income derived from property, and the identities of beneficial owners behind ownership structures. Indonesia has currently expressed support for this initiative and is targeting participation in the international property information exchange scheme starting in 2029.

However, behind this grand data exchange scheme, Indonesia must prepare early so that it does not end up as a mere tax transparency slogan. First, the government must strengthen its commitment by drafting regulations aligned with international standards. Implementing EOI on IPI requires a clear, operational, and adaptive legal foundation. The DJP needs to conduct intensive discussions with the OECD and benchmark against countries that have taken earlier steps in implementing EOI-IPI. This step is important to ensure that the regulations built can accommodate global standards without ignoring the legal characteristics and data availability within Indonesia’s land administration.

Second, the foundation of inter-agency coordination must be strengthened. The Ministry of Finance cannot work alone in preparing the implementation of EOI-IPI. Property ownership is often linked to land aspects, financial transactions, and law enforcement efforts. Therefore, strong commitment is needed from various ministries and agencies to support this programme, such as the Ministry of Agrarian Affairs and Spatial Planning/National Land Agency (ATR/BPN), the banking sector, and others.