We help Chinese tax residents clarify reporting obligations for overseas accounts, cross-border investments and foreign income, and turn legacy issues and future arrangements into an executable compliance path.
Clarify residency, obligations, tax basis, history and timing before acting.
01
Account information is already exchanged
CRS covers more than one hundred jurisdictions, with bank, custodian and investment account data exchanged annually to the country of tax residence—and the range of assets and jurisdictions covered keeps expanding.
02
Tax residency is complex to determine
Domicile, days of presence and centre of economic interests may point to several jurisdictions at once. Dual residency must be resolved under treaty tie-breaker rules, not assumptions.
03
The filing basis is hard to pin down
Characterising overseas investment gains, determining cost basis and converting currencies—across institutions with incomplete records—turns “what to file and how” into a professional judgement.
04
Exposure from past non-filing
Back taxes, late-payment surcharges, penalties and, in serious cases, criminal exposure. Voluntary disclosure and being discovered in an audit lead to very different outcomes.
05
The restructuring window is narrowing
Residency, entity and asset arrangements must be assessed before information is exchanged. Adjustments made afterwards leave little room and may create new tax and foreign-exchange issues.
02 / RESPONSE SYSTEM
Diagnose, reconcile, structure
Turn one-off anxiety into an executable, reviewable compliance arrangement.
01ASSESS
Clarify the obligations
Confirm tax residency, the scope of information exchange over accounts and assets, and the filing obligations and risk level for each year.
Organise transaction records and asset movements, compute gains and cost basis, and set the remediation and voluntary-filing path for past years.
Gain computationVoluntary filingPosition paper
03STRUCTURE
Structure the future
Plan residency, entities and asset structures compliantly, and establish an annual filing calendar and ongoing compliance routine.
StructuringFiling calendarOngoing counsel
03 / CAPABILITIES
Five service capabilities
We resolve specific filing issues and build long-term cross-border tax compliance.
01
CRS reporting diagnosis
Start from tax residency, assess the exchange exposure of accounts and assets, and define filing obligations and a timetable for each year.
Tax-residency determination
Exchange-scope assessment
Filing obligations and gaps
Multi-jurisdiction residency conflicts
02
Overseas-asset reconciliation and filing support
Turn records scattered across overseas banks, brokerages, insurers and trusts into filing-ready, explainable and archivable tax workpapers.
Cross-institution record reconciliation
Gain characterisation and cost basis
Filing positions and FX conversion
Annual filing data support
03
Legacy non-filing resolution
Grade the risk of past non-filing, design a voluntary-disclosure path and keep the matter within a manageable range.
Risk grading by year
Voluntary-disclosure design
Surcharge and penalty estimates
Criminal-risk assessment
04
Cross-border residency and structuring
Assess the tax consequences and implementation path of residency changes, family asset arrangements and outbound structures—on a compliant basis.
Residency-change feasibility
Family assets, policies and trusts
Outbound entity tax structures
Multi-jurisdiction rule alignment
05
Tax audits and disputes
Organise materials and consistent positions during inquiries and audits, and preserve rights of representation and remedy.
Inquiry and audit response
Representation materials
Review and litigation support
Cross-border dispute coordination
04 / SCENARIOS
Typical client situations
Mankun has handled extensive cross-border investment, funds-flow and tax compliance matters. Find the path that matches your situation.
Client situation
Years of overseas securities and fund gains, never filed
Records are spread across overseas institutions, cost basis is unclear, and there is concern that information exchange will trigger inquiries or audits.
Client situation
Offshore payroll, equity incentives and overlapping residencies
Offshore-entity salaries, equity incentives and multi-location living arrangements overlap; income characterisation and filing location need professional judgement.
Client situation
Overseas accounts, policies and trusts across jurisdictions
Family members hold different residencies and asset forms; each person's filing obligations and positions differ.
Client situation
Blurred lines between company and personal accounts
Mixed corporate and personal accounts and unclear treatment of retained profits and dividends raise CFC and double-taxation concerns.
Client situation
Received a tax inquiry or audit notice
Materials must be organised and positions aligned within a fixed window, preventing escalation into more serious legal consequences.
Tax treatment and legal boundaries are assessed together, so fixing a tax issue does not leave foreign-exchange or criminal exposure behind.
02
Many asset types, one consistent position
Bank, securities, fund, policy and trust accounts are handled on a single asset map, with consistent positions that withstand scrutiny.
03
Resolve the past, structure the future
Legacy remediation and future structuring are designed together, so remedial filings do not expose new issues.
04
China depth, global reach
Mainland China tax rules lead, coordinated with tax and legal resources across Hong Kong, Singapore, the US and other common jurisdictions.
06 / ENGAGEMENT
Flexible engagement models
Configured by stage, asset scale and urgency.
01First-time review
Diagnostic
Residency, exchange scope and obligation inventory
02Recurring filings
Annual filing support
Reconciliation, positions and filing workpapers
03Unfiled years
Legacy resolution
Risk grading, voluntary disclosure and audit playbook
04Planned changes
Residency & structuring
Feasibility, design and implementation support
05Notice received
Audit response
Materials, representation and dispute counsel
06Families and businesses
Ongoing counsel
Filing calendar, briefings and dedicated response
07 / DELIVERABLES
Ready-to-use deliverables
Usable directly by individuals, families, businesses and external advisers.
01Tax-residency analysis memo02Information-exchange risk map03Filing-obligation inventory04Overseas-asset gain workpapers05Filing position paper06Legacy risk report07Voluntary-disclosure plan08Surcharge and penalty estimates09Audit-response playbook10Restructuring implementation plan11Annual compliance calendar12Quarterly policy briefings
08 / FAQ
Frequently asked questions
Direct answers to the questions clients ask most.
CRS covers deposit accounts, custodian accounts, investment accounts and cash-value insurance contracts. Balances, interest, dividends and disposal gains are exchanged annually with your country of tax residence. The jurisdictions and asset types covered keep expanding, so treating overseas accounts as invisible is no longer realistic.
Yes. Chinese tax residents owe filing obligations on worldwide income, including interest, dividends and disposal gains in overseas accounts. Whether tax is actually payable depends on the character of the income, deductible costs and applicable treaties—but the filing obligation itself does not disappear because the account is offshore.
Voluntary reconciliation and filing offer far more room than being discovered in an audit. Voluntary resolution can usually be managed around back taxes and surcharges; once a formal audit begins, penalty multiples and criminal-risk assessment become much less favourable. The earlier the review, the more options remain.
Residency planning is a compliance question, not an avoidance tool. A change of tax residency must be supported by genuine living and economic arrangements, has no retroactive effect on past obligations, and—if done improperly—can trigger filing duties in two jurisdictions at once. Feasibility must be assessed case by case.
Interest and dividends are generally filed under their respective income categories; gains from transferring overseas equity, funds and similar assets are usually treated as “income from property transfer”. Characterisation and deductible costs differ by asset type and holding structure, and require analysis based on the substance of each transaction.
CRS TAX COMPLIANCE
Unsure about your filing obligations?
Tell us your residency situation, asset types and current position. We will help you assess your obligations and the right order of action.