（二）欧洲：44个 阿尔巴尼亚、安道尔、奥地利、比利时、保加利亚、克罗地亚、捷克共和国、丹麦、爱沙尼亚、法罗群岛、芬兰、法国（含新喀里多尼亚）、德国、直布 罗陀、希腊、根西岛、匈牙利、冰岛、爱尔兰、马恩岛、意大利、泽西岛、拉脱维亚、列支敦士登、立陶宛、卢森堡、马耳他、摩尔多瓦、摩纳哥、黑 山、荷兰、挪威、波兰、葡萄牙、罗马尼亚、俄罗斯联邦、圣马力诺、斯洛伐克、斯洛文尼亚、西班牙、瑞典、瑞士、乌克兰、英国。 在经济全球化与资本跨境流动日益频繁的背景下，跨境逃避税问题成为各国税收征管的共同挑战。为破解这一难题，提升全球税收透明度，经济合作与发 展组织（OECD）受二十国集团（G20）委托，于2014年发布《金融账户涉税信息自动交换标准》，其中核心组成部分"共同申报准则"（Common Reporting Standard，简称CRS），构建了一套标准化的跨境金融账户信息自动交换机制。截至2024年4月24日，全球已有118个国家和地区正式加入CRS体 系，通过多边协作打破税收信息壁垒，为跨境税源监管提供坚实支撑。以下为完整的参与国家和地区名单及相关说明。 本次分类严格遵循地理分类惯例，对跨亚欧大陆的国家（如塞浦路 ...

Group 1 - The core viewpoint of the articles highlights the significant increase in personal income tax revenue in China, driven by improved tax management and the inclusion of previously unreported overseas income [2][3][5] - In October 2025, personal income tax revenue reached 13,363 billion yuan, marking an 11.5% year-on-year growth, with a notable monthly increase of 27.3% [2][3] - The increase in personal income tax is attributed to enhanced tax collection efficiency, diversified tax sources, and active capital markets [2][3][5] Group 2 - The tax authorities have implemented a comprehensive approach to manage overseas income, utilizing data analysis and communication to ensure compliance among taxpayers [3][4] - The first large-scale collection of overseas income tax from Chinese residents has been initiated, leveraging tools like the Common Reporting Standard (CRS) for information exchange [4][5] - The capital market's activity has significantly contributed to the rise in capital income, which is a key component of personal income tax, with projections indicating a substantial increase in capital gains tax revenue in the coming years [6][7]

Group 1: Tax Revenue Growth - Personal income tax revenue in China reached 13,363 billion yuan from January to October 2025, showing a year-on-year growth of 11.5%, with October's growth rate jumping to 27.3% [2] - The increase in personal income tax is attributed to improved tax administration efficiency and diversification of tax sources, reflecting significant progress in tax governance capabilities [3][5] - The growth in personal income tax revenue is closely linked to enhanced tax collection efforts, particularly regarding overseas income [8] Group 2: Overseas Income Tax Compliance - Tax authorities in major cities have been actively notifying Chinese tax residents who invest in overseas stocks through platforms like Futu and Tiger Brokers to complete their tax declaration for overseas stock trading gains from 2022 to 2024 [1][5] - The implementation of the "Golden Tax Phase IV" has improved the monitoring of cross-border income and enhanced the identification of hidden income among high-net-worth individuals [5][6] - This year marks the first large-scale collection of overseas income tax from Chinese tax residents, utilizing tools like the Common Reporting Standard (CRS) for information exchange [7][8] Group 3: Factors Supporting Tax Revenue Growth - The active capital market has significantly contributed to the increase in capital income, which is a key driver of personal income tax growth [10][11] - High-income groups have shown resilience in their income, with substantial growth in stock option income and performance bonuses among professionals, further supporting tax revenue [11] - Economic recovery and low base effects from the previous year have amplified the growth rate of personal income tax [11]

Core Insights - The implementation of the Common Reporting Standard (CRS) marks the end of the "wild growth" era for cross-border e-commerce, pushing the industry towards unprecedented levels of financial and tax compliance [1][4] - CRS aims to enhance tax transparency by facilitating the automatic exchange of financial account information between participating countries, targeting cross-border tax evasion and money laundering [3][4] - Cross-border e-commerce companies must thoroughly understand CRS and proactively adjust their operations to ensure long-term stability and compliance [1][8] Understanding CRS - CRS is a global standard for the automatic exchange of financial account information, designed to combat cross-border tax evasion and money laundering [3] - It breaks down information barriers, requiring financial institutions in CRS participating countries to report account information of foreign residents to their respective tax authorities [3][4] - For example, a Chinese cross-border e-commerce company holding sales revenue in a foreign bank account will have its account information automatically reported to Chinese tax authorities [3] Impact on Cross-Border E-Commerce - Companies with numerous and disorganized overseas accounts are at high risk of scrutiny under CRS, as complex fund flows may be interpreted as tax evasion [5][6] - Businesses that conceal overseas income by not repatriating funds or failing to report them to tax authorities are particularly vulnerable to CRS enforcement [5][6] - Companies using personal accounts for business transactions face risks of tax evasion charges and potential legal violations, as personal account information will also be reported [6] Compliance Strategies - Companies should conduct a thorough review of all overseas accounts, consolidating funds into a few well-managed accounts and ensuring clear documentation of all transactions [7] - There is a need for proactive and accurate tax reporting of all overseas income to Chinese tax authorities, leveraging available tax incentives for cross-border e-commerce [7] - Establishing a compliant operational structure is essential, including separating personal and business finances and maintaining comprehensive records for all cross-border transactions [7][8] Future Outlook - The implementation of CRS is reshaping the competitive landscape of cross-border e-commerce, favoring compliant businesses while eliminating non-compliant competitors [8] - Companies that embrace CRS as a core strategy will not only mitigate risks but also position themselves for future growth and international expansion [8]

Group 1 - The Chinese tax authorities have intensified scrutiny on residents' overseas investment income, leading to notifications for tax payments on such income in cities like Beijing, Shanghai, and Hangzhou [1] - The implementation of the Common Reporting Standard (CRS) in China since September 1, 2018, facilitates automatic exchange of non-resident financial account information among participating countries to combat cross-border tax evasion [1] Group 2 - The classification of cash values and dividends from Hong Kong insurance policies as taxable income under the Individual Income Tax Law of the People's Republic of China is a pressing issue for investors [2] - According to the law, Chinese tax residents are required to pay taxes on global income, including interest, dividends, and bonuses, at a rate of 20% [2] Group 3 - The definition of "dividends" in tax law typically refers to profits distributed based on investment relationships such as debt or equity holdings [3] - There is a distinction between insurance policy dividends and traditional dividends, as policyholders are not shareholders or creditors of the insurance company [5] Group 4 - The debate continues regarding whether the appreciation in value of certain insurance products, such as dividend insurance and overseas savings insurance, constitutes taxable income [6] - Current regulations do not specifically tax the dividends from Hong Kong savings-type insurance policies, and such income is not categorized as capital gains [6] Group 5 - Internationally, many Western countries have broader tax implications for investment income, with specific provisions in the U.S. tax code regarding the taxation of insurance policy cash values and benefits [7] - Chinese tax residents are required to report their global income, including overseas insurance policy values, and must stay informed about policy changes to ensure compliance [7]

Core Viewpoint - The article emphasizes the importance of personal income tax and its threshold as a key element in determining taxpayers' pre-tax deductions, which directly impacts their economic burden and is a focal point for public concern [2][4][6]. Policy Context - The Chinese government aims to improve the personal income tax system by gradually establishing a combined comprehensive and classified tax system, as highlighted in various party congress reports [2][3]. - The 2025 National People's Congress is expected to see proposals for increasing the personal income tax threshold or enhancing deductions, particularly in high-cost areas like Beijing, Shanghai, Guangzhou, and Shenzhen [3][4]. Current Tax Structure - The current personal income tax threshold has remained unchanged since 2018, set at 5,000 yuan per month, with 64% of personal income tax revenue derived from wage and salary income, effectively making it a "salary tax" [3][4]. - The classification of income for tax purposes has been expanded from four categories to nine, including new categories such as business income and capital gains, to enhance revenue management [3][4]. Tax Deductions and Fairness - The special additional deductions for personal income tax have been continuously improved, covering various living expenses such as education, medical care, and housing [4][5]. - The tax system aims to reduce income disparity through differentiated tax burdens, ensuring that high-income earners contribute a larger share of taxes while lower-income individuals may not pay taxes at all [4][5][9]. Challenges in Tax Administration - There are significant challenges in regulating non-wage income compared to wage income, leading to potential inequities in tax burdens [10][11]. - The current system struggles to adequately cover flexible employment and new economic sectors, resulting in mismatches in tax policy application [10][11]. Future Directions - Future reforms may focus on increasing the threshold for personal income tax and optimizing the tax structure to ensure sustainability while promoting fairness [12][14]. - The introduction of a progressive deduction system based on income levels could help address disparities and enhance the equity of the tax system [15][14].

Core Viewpoint - The tightening of account opening policies for cross-border internet brokers targeting mainland residents has been implemented, with several firms, including Futu Holdings and Interactive Brokers, now requiring proof of long-term overseas residence or employment instead of the previous "stock proof" method [1][2][5]. Group 1: Policy Changes - Interactive Brokers has updated its account opening requirements, necessitating long-term overseas living or working proof for mainland investors, as the previous stock proof method is no longer accepted [2][5]. - Other brokers, such as Futu Holdings and Long Bridge Securities, have also adjusted their policies to comply with regulatory requirements, limiting account openings to those who can provide valid overseas proof along with a mainland ID [5][6]. Group 2: Regulatory Environment - The regulatory environment for cross-border internet brokers has been tightening since 2021, with the People's Bank of China and the China Securities Regulatory Commission (CSRC) emphasizing the need for compliance and the prohibition of illegal financial activities targeting mainland investors [7][8]. - The CSRC has been actively working to rectify illegal cross-border operations, including prohibiting firms from soliciting mainland investors and opening new accounts without proper licensing [7][8]. Group 3: Market Impact - The increased account opening requirements are expected to significantly raise the barriers for mainland residents wishing to invest through cross-border internet brokers, potentially leading to a decline in new account openings [5][6]. - The changes come amid a broader context of enhanced tax compliance measures in China, particularly under the Common Reporting Standard (CRS), which has prompted many investors to seek brokers in non-CRS jurisdictions [4][6].

Group 1: Cross-Border Regulatory Upgrades - The Cayman Islands has introduced the Beneficial Ownership Transparency Law effective January 2025, which includes previously exempted funds under the new regulatory framework [2] - The British Virgin Islands (BVI) will implement a new beneficial ownership information reporting system starting January 2025, requiring all BVI companies to comply with enhanced disclosure requirements [2] - The new regulations mandate regular identification of beneficial owners and compliance measures for funds in the Cayman Islands [2] Group 2: China's Tax Administration Evolution - Since 2020, China's tax administration has entered a "data-driven" era, with increasing prevalence of penetrating supervision [3] - Tax authorities in various provinces have identified cases of unreported foreign income, leading to demands for tax payments and penalties [3] - The revised Tax Collection and Administration Law expands the scope of tax audits to include third parties, enhancing the power of tax authorities to investigate hidden beneficial owners [3] Group 3: Penetrating Supervision of Offshore Structures - Multi-layer offshore structures are increasingly subject to penetrating supervision, allowing tax authorities to trace and identify ultimate beneficial owners [4] - All fixed beneficiaries of trusts must be reported, and trustees retaining certain powers may be deemed actual controllers [4] - Starting in 2025, protectors of trusts will also be required to disclose their identities, further exposing hidden beneficiaries [4] Group 4: CRS Reshaping International Tax Order - The Common Reporting Standard (CRS) defines tax residency based on actual residence and economic interests rather than nationality [5] - Individuals with a residence in China or those residing in China for over 183 days in a tax year are classified as tax residents, subject to income tax on global earnings [5] - Financial institutions are required to identify and report actual controllers of passive non-financial entities under CRS [6] Group 5: Legal Compliance Over Geographical Arbitrage - The OECD's CRS facilitates automatic exchange of tax information among participating jurisdictions, enhancing tax compliance [9] - Prior to CRS, countries relied on bilateral agreements for tax information exchange, which were often inefficient and limited in scope [9] - The CRS is seen as a global extension of the U.S. FATCA, promoting a more standardized approach to tax information exchange without punitive measures like withholding taxes [10] Group 6: Historical Context and Future Outlook - The CRS framework was launched in 2014, with China committing to its implementation in 2017, leading to extensive international cooperation on tax information exchange [11] - As of June 2025, over 120 countries and regions are expected to participate in the CRS, with more developing countries likely to join [11] - The evolution of tax compliance reflects a shift from geographical arbitrage to legal adherence, emphasizing transparency and compliance as the new standards for tax safety [12]

Core Viewpoint - China is strengthening the taxation of residents' overseas income, including income from stock trading abroad, which is subject to a 20% tax rate according to personal income tax law [1][12]. Group 1: Taxation on Overseas Income - Taxpayers have recently received notifications from tax authorities regarding the need to declare overseas income and pay corresponding taxes [1]. - The taxation on overseas stock trading is classified as capital gains, and individuals must pay taxes on each transaction, with the possibility of offsetting gains and losses within the same tax year [3][8]. - China has joined the Common Reporting Standard (CRS) for automatic exchange of tax information, allowing tax authorities to access data on residents' overseas financial accounts [3][11]. Group 2: Tax Treatment of Specific Investments - For Hong Kong stock investments, capital gains are exempt from personal income tax if traded through the Stock Connect program until June 2025; otherwise, a 20% tax applies [5]. - For U.S. stock investments, capital gains are also taxed at 20%, calculated based on the difference between selling and buying prices minus reasonable expenses [7]. - Dividend income from H-shares incurs a 20% withholding tax, while dividends from other Hong Kong stocks may not be subject to withholding but still require self-declaration [6][9]. Group 3: Tax Filing and Documentation - Taxpayers must file their overseas income tax returns through the Chinese tax authority's electronic system, even if taxes have already been paid abroad [10]. - Key documentation includes transaction records, proof of tax payment from foreign brokers, and bank statements [11]. - Failure to declare overseas income may result in penalties, including back taxes, late fees, and fines [12].

Core Viewpoint - The Chinese tax authorities are intensifying scrutiny on overseas investment income, requiring tax residents to declare and pay taxes on capital gains from foreign stock trading starting from 2025 [3][6][9]. Group 1: Tax Regulations and Compliance - Starting in early 2025, tax authorities will notify Chinese tax residents via SMS, phone calls, and tax apps to declare overseas stock trading income for the years 2022 to 2024 [3][6]. - The tax rate for overseas capital gains is set at 20%, with no minimum threshold or special deductions applicable [6][9]. - Tax residents are required to report their overseas income annually between March 1 and June 30 through the individual income tax app, including transaction evidence [6][14]. Group 2: Impact of CRS and Enforcement - The Common Reporting Standard (CRS) has enhanced the ability of tax authorities to track overseas accounts, leading to increased enforcement of tax compliance for overseas investments [9][12]. - Previously, enforcement was lax, but the introduction of CRS has allowed tax authorities to monitor accounts more effectively, including those with balances below $1 million [9][12]. - Tax compliance is now viewed as a mandatory obligation rather than an option, especially for high-income individuals with overseas assets [9][10]. Group 3: Investment Channels and Strategies - Investors are exploring compliant and tax-efficient overseas investment channels, such as QDII funds, which allow investment in foreign markets through domestic financial institutions [18][19]. - The Hong Kong Stock Connect program enables investors to trade Hong Kong stocks without capital outflow, maintaining compliance with domestic regulations [19]. - Cross-border ETFs listed in China provide another avenue for investment in foreign indices without incurring capital gains tax [20].