WHAT ARE THE COMMITMENTS OF MAINLAND CHINA AND HONG KONG
By: Fintax
CARFBasic positioning
CARFIt is a framework for the automatic exchange of cross-border tax information for encrypted assets, with encrypted asset service providers as the subject of information declarations, to support tax authorities in judicial districts in obtaining encrypted transaction information related to national taxpayers。
Global implementation progress and timing
Based onOECDInformation released by the Global Forum, as of2025By the end of the year76Commitment by country and regionCARF) and will be set aside in batches。
First judicial district plans2027First automatic exchange of information in the year, mainly in the United Kingdom and EU member StatesWait; second judicial district plan2028Full implementation year, including Singapore, the United Arab Emirates and Hong Kong, ChinaWaitI don't know。
In accordance with the institutional arrangements, the collection of relevant transaction data will be initiated one year in advance from2026Since then, encrypted asset service providers are required to systematically collate information on declared transactions。
FIGURE 1: OVERVIEW OF THE CARF IMPLEMENTATION PROCESS IN MAJOR JURISDICTIONS
Hong Kong, China: Clear participation and progress by schedule
In these arrangements, Hong Kong, China, has made a clear commitment to implementCARFIt will follow the international timetable。
Hong Kong Plan2027Commencement of data collection on encrypted asset transactions starting with2028Automatic exchange of tax-related information with other cooperating jurisdictions in the year。
Encrypted asset service providers operating under the Hong Kong regulatory framework need to establish corresponding data setsRuleWith regard to the reporting mechanism, the relevant declared transactions will be incorporated into the cross-border information exchange process。
Mainland China: not committed and not implemented
In contrast, mainland China is not yet in placeCARFMadeImplementation of commitments。
As of this stage, mainland China is not includedCARFNone of the implementationsOECDListed as judicial districts of relevance but not yet committed to participation。
Under the existing regulatory framework, the continent has adopted a restrictive approach to encrypted currency transactions, which does not exist in the country to be includedCARFLegally encrypted asset service providers of the declaration system are therefore not involved in the short termCARFInstitutional conditions for routine exchange of information。
Future possibilities and realistic judgements
It's important to note that mainland China2018Full implementation sinceCRSExperience in financial account exchange。
If future policies for the regulation of encrypted assets are adjusted, the continent will have institutional and technical interfacesCARFconditions。
But in the current policy environment2027YearCARFThe likelihood of mainland China joining the framework remains low during the start-up and subsequent years。
