Mr. Chen, a foreign trade executive in Shenzhen, set up a company in Hong Kong last year and registered a shell company in the British Virgin Islands (BVI), thinking that by routing his funds through these entities, he could “go underground.” Lately, however, the more he thinks about it, the more uneasy he feels.

What’s causing him concern is the CRS 2.0, which is now being implemented. This update no longer focuses solely on whether you have offshore accounts; instead, it seeks to determine who controls the accounts, who benefits from them, and whose information should be exchanged.

This article clearly explains the three key changes in CRS 2.0, helping you determine whether you’re affected and how to respond.

01

What is CRS 2.0?

CRS, which stands for the Common Reporting Standard, is a global standard for the automatic exchange of tax information introduced by the OECD in 2014. Simply put, information on financial accounts held overseas by Chinese tax residents will be automatically exchanged with Chinese tax authorities by the local tax authorities.

In September 2018, China launched its first exchange of financial account information under the CRS. By 2026, this framework underwent a systematic upgrade, which the industry refers to as CRS 2.0.

Hong Kong’s “Taxation (Amendment) (Automatic Exchange of Information) Bill 2026” was published on March 27, 2026, and introduced to the Legislative Council for first reading on April 1; it is expected to take effect on January 1, 2027. It is accompanied by the Crypto-Asset Reporting Framework (CARF).

If you’re facing a similar situation—you have a company or bank account in Hong Kong or the BVI but haven’t yet sorted out your tax residency status and filing requirements—feel free to scan the QR code to contact Qicaiying’s online customer service (WeChat/Phone: 18620388671). We’ll help you sort out this compliance process from the very beginning.

02

Change 1: Inclusion of Cryptocurrencies in Tax Filings

The original CRS covered only traditional financial assets such as bank deposits, stocks, mutual funds, and insurance. CRS 2.0 includes crypto assets in its definition for the first time: Bitcoin, Ethereum, stablecoins, NFTs, and central bank digital currencies are all covered.

Cryptocurrency trading platforms, custodians, and entities that invest in cryptocurrencies are all designated as reporting entities and are required to comply with KYC and reporting obligations. In other words, your records of buying and selling cryptocurrencies on the Hong Kong Exchange will eventually be included in the global automatic exchange of information network.

If you think you can “disappear” by converting the money in your bank account into Bitcoin, that idea is basically out of the question under CRS 2.0.

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03

Change 2: Individuals with dual identities can no longer “choose one to report”

Under the previous CRS, individuals with multiple tax residencies were allowed to “choose one jurisdiction” to file their returns with, meaning they could file in only one jurisdiction. Under CRS 2.0, this has changed to require filing with all relevant tax jurisdictions simultaneously.

For example, if you are a tax resident of both the mainland and Hong Kong, you may have previously chosen to file your taxes only in Hong Kong; now, your account information will be reported to both the mainland tax authorities and the Hong Kong Inland Revenue Department. The path of using a Hong Kong residency to evade mainland tax oversight has been blocked.

To date, information on the financial assets of Chinese tax residents in more than 120 CRS-participating countries and regions around the world is automatically exchanged back to China each year.

04

Change 3: Offshore Structures Are Fully Pierced Through

In the past, many people used shell companies in the British Virgin Islands (BVI) and the Cayman Islands to hold accounts and assets, which were nominally owned by “companies” rather than individuals. CRS 2.0 requires financial institutions to look through multi-layered nested structures layer by layer, all the way to the ultimate beneficial owner.

Traditional “tax havens” such as the BVI and the Cayman Islands began collecting data in accordance with the new CRS 2.0 standards on January 1, 2026, and will begin formal data exchange in 2027. Shell companies, offshore trusts, and nominee arrangements will all be subject to look-through scrutiny.

The scrutiny criteria have also been upgraded from “formal review” to “substantive review”—it is no longer enough to simply have a shell company; there must be genuine business activities and substantive operations, otherwise the company will still be subject to a “look-through” review.

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05

Which ones will be exchanged, and which ones won't?

The following information will be exchanged: bank deposit balances and transaction records; securities such as stocks, mutual funds, and bonds; the cash value and dividends of insurance policies; cryptocurrency account balances and trading gains (starting in 2028); and information on the beneficial owners of trusts and offshore companies.

The following will not be directly exchanged: tangible assets such as overseas real estate, jewelry, and works of art; equity interests in privately held companies held directly by individuals; and assets located in jurisdictions not covered by the CRS (although more than 120 countries have already joined the system).

In other words, for those who conduct genuine business, have a clear tax status, and engage in actual operations, CRS 2.0 merely increases transparency; it is the structures that truly rely on information asymmetry that will be reshaped by this round of reforms.

06

How Should Ordinary People Respond?

First, stop trying to “hide.” It’s much safer to truthfully report all your tax residency statuses and pay the taxes you owe according to the rules than to face retroactive tax assessments later.

Second, ensure that the process for holding overseas financial assets is well-organized: Hong Kong bank cards, Hong Kong-licensed brokerage firms, genuine business contracts, and transaction records—not a single one should be missing. With a clear chain of documentation, the exchange of information poses no risk.

Third, be wary of under-the-table schemes promising to “guarantee account openings” or “guarantee tax avoidance.” In the CRS 2.0 era, compliance frameworks have been restructured, and traditional optimization models that relied on information asymmetries are becoming ineffective.

If you’re facing a similar situation—wanting to diversify your assets overseas but worried that CRS 2.0’s look-through review might cause you to cross the line—feel free to scan the QR code to contact Qicaiying’s online customer service (WeChat/Phone: 18620388671). We’ll help you sort out this compliance process from the very beginning.

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