The new policy
On 24 July 2026, the Ministry of Finance and State Taxation Administration issued Announcement 21 on offshore-trust individual income tax. Begin by distinguishing residency, who funds and controls the trust, and asset sources.
Source: official policy or guidance ↗
More than “tax on the way in and out”
The announcement distinguishes resident funding, ongoing income and other situations. Trust income already taxed as required for a resident is not taxed again on actual distribution. It should not be described as one universal double-tax result.
Source: official policy or guidance ↗
Check tax bases and status changes
The Ministry’s explanation describes the funding tax base for residents’ assets such as shares as market value less original cost and reasonable expenses, rather than automatically the full asset value. Changes to non-resident status and termination have specific treatment; an overseas status document does not replace assessment.
Source: official policy or guidance ↗
Prepare a review file
Our coordination focuses on the deed, structure, valuation and cost evidence, income, distributions and foreign-tax records. Legal separation, governance and tax are reviewed separately before actions are sequenced. Existing trusts should have historical and transitional treatment checked promptly by tax advisers.
This is general policy information and a planning perspective. Individual applicability requires review. Contact [email protected] to organise questions for professional assessment.