CRS Tax Compliance

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.

01 / PRESSURE

What to assess first under CRS

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.

Residency analysisObligation inventoryRisk grading
02RECONCILE

Reconcile the history

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.

05 / METHOD

How Mankun works

Tax rules, legal boundaries, asset facts and cross-border coordination handled together.

01

Tax and legal judgement together

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.

Discuss tax compliance