共同申报准则(CRS)
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杜国栋|美国+40国拒绝CRS!海外资产追索的盲区?
Sou Hu Cai Jing· 2025-10-25 09:18
Core Viewpoint - The Common Reporting Standard (CRS) is a crucial tool for combating cross-border tax evasion and enhancing asset transparency, but the lack of participation from certain countries creates information gaps that hinder asset recovery efforts [1][4]. Group 1: CRS Framework and Functionality - The CRS, introduced by the OECD in 2014, facilitates automatic exchange of financial account information among over 120 countries by 2025, aiding tax authorities in tracking global asset flows [1][4]. - Financial institutions are required to conduct due diligence on non-resident accounts and report account holder information to their domestic tax authorities, which is then exchanged with other participating countries [3][4]. - The CRS mandates the identification of "Controlling Persons" for entities, ensuring that beneficial ownership information is reported to relevant tax authorities [3][4]. Group 2: Impact of Non-Participation - Approximately 40 countries are not participating in the CRS as of 2025, primarily developing nations and small island states, which creates barriers to asset recovery and tax compliance [4][14]. - The absence of CRS participation means that financial institutions in these countries are not obligated to report non-resident account information, complicating cross-border debt recovery efforts [4][14]. - The United States, as a major financial center, utilizes the Foreign Account Tax Compliance Act (FATCA) instead of CRS, leading to a one-way information exchange that further complicates global asset tracing [5][14]. Group 3: Challenges in Asset Recovery - The lack of CRS participation results in significant obstacles for creditors seeking to obtain information on debtors' assets in non-CRS countries, creating a "black hole" of property information [14][15]. - For instance, a Chinese tax resident holding assets in a U.S. bank through a BVI company would not have their information automatically reported to Chinese tax authorities, complicating legal recourse [15]. - China has successfully recovered substantial tax revenues since implementing CRS in 2017, but still faces challenges in accessing information from non-CRS countries, relying on limited bilateral agreements [15].
CRS+时代:个人境外所得税务合规挑战和应对
Sou Hu Cai Jing· 2025-10-20 11:59
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]
多家APP境内下架,互联网券商全面收紧内地居民开户
21世纪经济报道· 2025-09-11 07:01
Core Viewpoint - The article discusses the tightening of account opening policies for cross-border internet brokers targeting mainland Chinese residents, with predictions that the "existing proof" account opening channel may be completely shut down in the future [1][10]. Summary by Sections Account Opening Policy Changes - Several institutions, including Futu Holdings and Interactive Brokers, have canceled the "existing proof" account opening method, now requiring proof of long-term residence or work abroad [1][4]. - The official app of Interactive Brokers has been removed from mainland app stores, indicating a significant increase in account opening thresholds for mainland investors [4][6]. Regulatory Environment - The tightening of regulations on cross-border internet brokers has been ongoing since 2021, with the People's Bank of China stating that these brokers operate illegally within China [9]. - The China Securities Regulatory Commission (CSRC) has been actively working to rectify illegal cross-border operations, emphasizing the need to curb new accounts while allowing existing investors to continue trading [10]. Impact on Investors - Many investors in Hong Kong and U.S. stocks have received tax notifications this year, prompting some to seek brokers in non-CRS countries to avoid tax information exchange [1][3]. - The new requirements for account opening include providing various documents such as utility bills, tax documents, and rental agreements, all dated within the last three months [7].
新闻 | 大成律师为中信银行(国际)私人银行开展CRS专题培训
Sou Hu Cai Jing· 2025-06-17 03:55
Group 1 - The training conducted by Dachen Financial Committee and CITIC Bank (International) Private Banking focused on the Common Reporting Standard (CRS) to enhance understanding of legal regulations and compliance in cross-border financial services [2][3] - The first part of the training covered the legal framework and operational mechanisms of CRS, highlighting the differences in implementation across jurisdictions and potential legal risks for financial institutions [2] - The second part addressed the current status and characteristics of CRS tax audits in China, emphasizing the focus on high-net-worth individuals, strict review of information submitted by financial institutions, and in-depth scrutiny of cross-border transactions [2] Group 2 - The third part of the training analyzed CRS compliance issues related to family wealth of Chinese tax residents, discussing the impact of CRS on wealth structure, asset allocation, and tax planning [3] - The training provided a comprehensive understanding of CRS, laying a solid foundation for compliance management in cross-border financial services, enabling CITIC Bank (International) Private Banking to offer more professional and efficient services [3] Group 3 - 49 business areas were recognized in the "Chambers Greater China Guide 2025" [4] - 27 business areas/regions were listed in the Legal 500 2025 annual rankings [4] - 9 awards were received in the "Commercial Law" 2024 annual excellence awards [4] - 30 business areas were recognized in the 2025 LEGALBAND top law firms ranking in China [4]
CRS信息交换下的个人海外资产收入申报与税务合规 | 一键预约直播
私募排排网· 2025-06-16 03:54
Core Viewpoint - The article emphasizes the importance of understanding international tax regulations, particularly the Common Reporting Standard (CRS), for investors considering or already engaging in overseas asset allocation as global markets become more accessible and diversified [2]. Group 1: Event Overview - The event titled "Personal Overseas Asset Income Declaration and Tax Compliance under CRS Information Exchange" aims to provide insights into the CRS information exchange mechanism [3]. - The event is scheduled for June 16, 20:00, and will be available for viewing via a QR code or mini-program [4]. Group 2: Expert Introduction - Mr. Luo Dawei, a tax partner at RSM China with over 20 years of experience in tax services, will be the guest speaker [8]. - His expertise includes tax services related to mergers and acquisitions, IPOs, supply chain tax optimization, cross-border investment structuring, and private equity fund consulting [9]. Group 3: Company Background - RSM is a leading global audit, tax, and consulting network focused on mainstream markets, with a global revenue exceeding $8 billion in 2022, reflecting a 15% growth [10]. - RSM ranked 6th in the International Accounting Bulletin's world accounting network rankings in 2022, recognized for its professional service quality and market reputation [10].