在全球经济深度融合的背景下，跨境税务透明度已成为维系国际税收治理体系有效运转的核心议题。面对金融市场的快速发展，传统税务合规框架在覆盖 范围与监管效能上日渐乏力。为此，全球自动信息交换机制逐步演进为共同申报准则（Common Reporting Standard，简称CRS），构建起跨国税务信息交 换的基础性框架。自CRS落地实施以来，各主要司法辖区已基本完成金融机构尽职调查与年度信息申报制度建设，并依托税务信息自动交换合作网络实现 常态化跨境自动交换，全球税收透明度与跨境合规约束显著增强。 例如，根据OECD发布的税基侵蚀与利润转移行动计划的最新指引，双边税收协定中的"居民身份判定规则"已不再被认可为判定多重税收居民身份的合法 依据。税务居民身份的判定，本质上应基于各国国内税法的规定，强调从信息采集的源头遏制不实申报，从而系统性提升跨境税务信息申报的准确性、合 规性与整体数据质量。 在实践中，这可能也意味着，对于拥有多重税收居民身份或跨境资产配置复杂的高净值个人而言，更严格的核实机制将显著压缩其在不同税收管辖区间进 行"选择性申报"的操作空间，进而促使其在税收居民身份认定与资产申报口径上保持全面一致。[4] ...

Core Insights - The article discusses the increasing transparency in tax regulation for Chinese tax residents, particularly regarding overseas income, driven by the implementation of the Common Reporting Standard (CRS) [1][2][3] Group 1: CRS Implementation and Tax Compliance - The CRS has enabled Chinese tax authorities to access detailed information about tax residents' overseas financial accounts, including balances and transaction details since its introduction in 2017 [2] - Recent announcements from tax authorities in regions like Shanghai and Shandong indicate a focused effort on compliance checks for high-net-worth individuals regarding unreported overseas income [2][3] - Tax authorities are actively conducting audits and requiring self-assessments from taxpayers for overseas income from 2022 to 2024, highlighting a shift towards more precise tax governance [2][3] Group 2: Personal Income Tax Scrutiny - There is a notable increase in the enforcement of annual personal income tax reconciliations, with tax departments issuing notices to individuals who have not completed their tax filings for previous years [3] - Tax authorities are mandating that individuals report all domestic and foreign income accurately, reflecting a comprehensive approach to income tax compliance [3] Group 3: Anti-Avoidance Measures - Tax authorities are intensifying scrutiny on offshore structures and controlled foreign corporations (CFCs), even in the absence of formal regulations for individuals [4] - Investigations are being conducted on profits retained in shell companies established in low-tax jurisdictions, with demands for financial statements and proof of business substance [4] Group 4: Taxpayer Guidance and Compliance Strategies - Taxpayers are advised to clearly understand their obligations regarding the reporting of overseas income, including various types of income such as salaries, dividends, and rental income from overseas properties [6][10] - It is recommended that taxpayers proactively communicate with tax authorities to clarify any ambiguities regarding the taxation of overseas income and to seek guidance on complex scenarios [8] - Maintaining accurate records and documentation for overseas income is crucial for compliance, with a recommendation to retain such records for at least five years [12][18] Group 5: Future Trends in Tax Regulation - The article emphasizes that cross-border tax regulation will remain a key focus for tax authorities, with expectations of stricter oversight on personal overseas income and CFCs in the coming years [15] - The anticipated expansion of the CRS to include more asset types, such as cryptocurrencies, indicates a trend towards greater regulatory scrutiny and transparency [14] - Taxpayers are encouraged to adopt a proactive approach to tax planning and compliance, leveraging professional advice to navigate the evolving regulatory landscape [13][20]

Core Viewpoint - The article discusses the increasing scrutiny and regulatory measures regarding the declaration of overseas income for Chinese taxpayers, particularly in light of the Common Reporting Standard (CRS) and the implementation of the Golden Tax Phase IV system, which enhances the transparency of cross-border financial activities [2][7][12]. Group 1: Overview of Tax Compliance - The annual personal income tax settlement period closed on June 30, 2025, but tax authorities continue to send reminders to taxpayers holding overseas assets, indicating a tightening of tax compliance [2][6]. - The CRS network now covers over 150 jurisdictions globally, facilitating the exchange of financial account information and increasing the transparency of overseas income [2][7][12]. - Taxpayers are advised to systematically review their tax compliance and identify risks, including clarifying their tax residency status and understanding the tax implications of their overseas income and asset allocations [2][6][12]. Group 2: Regulatory Developments - The tax authorities are focusing on individuals who have not declared overseas income, especially those who have received income from overseas investments in Hong Kong and the US [6][8]. - The implementation of the Golden Tax Phase IV system is expected to enhance the monitoring of cross-border income and asset information, making it technically feasible to track overseas earnings [7][12]. - Taxpayers are reminded that all global income must be declared, and there is no threshold for declaring small amounts of overseas income [11][12]. Group 3: Common Misunderstandings - Many taxpayers mistakenly believe that income already taxed overseas does not need to be declared in China, or that certain types of income, such as interest from domestic sources, are exempt from tax [8][10]. - Taxpayers may also overlook the requirement to declare capital gains or dividends from overseas investments, assuming that small amounts do not need to be reported [11][12]. - The article emphasizes that tax residency is determined by various factors, and individuals may still be considered tax residents in China even if they reside abroad for extended periods [10][12]. Group 4: Future Tax Compliance Trends - The article highlights the importance of proactive tax compliance, urging taxpayers to accurately assess their global income and maintain proper documentation for potential audits [16][17]. - High-net-worth individuals are particularly encouraged to view tax compliance as a critical aspect of their financial management, given the complexities involved in declaring overseas income [16][17]. - Legal and compliant tax planning strategies are suggested, such as utilizing investment vehicles that may offer tax benefits while adhering to Chinese tax laws [17].