中国离岸信托个人所得税申报过渡期届满 部分纳税人仍在观望

中国离岸信托个人所得税申报的90天免滞纳金过渡期于2026年10月22日正式届满1。从这一日期起，历史未缴税款的申报将被加收滞纳金1。中国财政部与国家税务总局于7月24日发布新规，大幅扩大了离岸信托的纳税义务范围，规定居民个人装入离岸信托的财产及信托存续期间产生的特定收益都可能产生纳税义务1。

新规出台后，部分高净值人士已选择主动申报补缴税款。安理律师事务所税务合伙人叶永青表示，由其团队接手的相关客户均已完成申报缴税1。然而，也有纳税人因对征税范围、税款金额等问题存在疑虑而继续观望1。目前，中国官方尚未公开披露已申报存量离岸信托的具体比例或统计数据1。

The 90-day transition period for offshore trust personal income tax filing in China expired on October 22, 2026, marking the end of a grace period during which taxpayers could settle historical unpaid taxes without incurring late fees.1 Beginning after this date, any previously unreported offshore trust tax obligations will be subject to additional penalties.1

The Chinese Ministry of Finance and State Administration of Taxation introduced sweeping new regulations on July 24, 2026, significantly tightening individual income tax oversight of offshore trusts and expanding the scope of taxable obligations.1 Under the revised rules, both the assets placed by resident individuals into offshore trusts and certain income generated during the trust's duration may trigger tax liability.1

While some affluent individuals have already completed their supplementary tax payments, others remain hesitant to file, citing uncertainties about the scope of taxation and the amounts owed.1 According to Ye Yongqing, a tax partner at Anli Law Firm, all clients under his team's management have completed their tax filings.1 However, official authorities have not yet publicly disclosed the specific proportion or statistical data regarding the number of historical offshore trusts that have been reported.1