On July 24, 2026, China’s Ministry of Finance (MOF) and the State Taxation Administration (STA) jointly issued Announcement No. 21 of 2026 alongside Announcement No. 15 of 2026. Taking immediate effect, these landmark regulations clarify the Individual Income Tax (IIT) obligations for mainland China tax residents across the entire lifecycle of offshore trusts (establishment, operation, and liquidation).
Historical tax deferral strategies involving offshore trusts (BVI, Cayman, Jersey, Singapore) are no longer viable. PRC tax authorities now enforce a full “look-through” approach, supported by automated data exchange under the Common Reporting Standard (CRS).
We are pleased to bring you a critical update regarding Hong Kong’s asset management tax landscape. The Inland Revenue (Amendment) (Preferential Tax Regimes for Funds, Family-owned Investment Holding Vehicles and Carried Interest) Bill 2026 was gazetted on 12 June 2026 and introduced into the Legislative Council. Once enacted, these groundbreaking measures will take retrospective effect from the Year of Assessment 2025/26.