Clarification: Will Chinese users' cryptocurrency data be handed over to the tax authorities?

Author | FinTax

Basic Position of CARF

CARF is a cross-border tax information automatic exchange framework for crypto assets, with crypto asset service providers as the reporting entities, used to support tax authorities in various jurisdictions in obtaining information related to crypto transactions of their taxpayers.

Global Implementation Progress and Timeline

According to information released by the OECD Global Forum, by the end of 2025, 76 countries and regions have committed to implementing CARF, with phased rollout of the system.

The first batch of jurisdictions plans to conduct their first automatic information exchange in 2027, mainly including the UK and EU member states; the second batch plans to fully implement in 2028, including Singapore, the UAE, and Hong Kong.

According to the system arrangement, the collection of relevant transaction data will begin one year in advance. Starting from 2026, crypto asset service providers will need to systematically organize reportable transaction information.

Hong Kong, China: Clear participation and phased implementation

In the above arrangement, Hong Kong has explicitly committed to implementing CARF and will advance related work according to the international timetable.

Hong Kong plans to start collecting crypto asset transaction data in 2027 and to conduct automatic cross-border tax information exchange with other participating jurisdictions in 2028.

Crypto asset service providers operating under Hong Kong’s regulatory framework are required to establish corresponding data compliance and reporting mechanisms. Relevant reportable transactions will be included in the cross-border information exchange process.

Mainland China: Not yet committed and not within the scope of implementation

In contrast, Mainland China has not yet made any commitments to implement CARF.

As of now, Mainland China is not included in any of the CARF implementation batches, nor has it been listed by the OECD as a jurisdiction that is relevant but has not yet committed to participate.

Under the current regulatory framework, Mainland China adopts a strict stance on crypto trading activities. There are no legitimate crypto asset service providers within the country that can be included in the CARF reporting system. Therefore, there are no institutional conditions for participating in routine CARF information exchange in the short term.

Future Possibilities and Practical Judgments

It should be noted that Mainland China has fully implemented CRS since 2018 and has mature experience in financial account information exchange.

If future crypto asset regulatory policies are adjusted, Mainland China may have the conditions to connect with CARF at the system and technical levels.

However, given the current policy environment, the likelihood of Mainland China joining the framework in 2027 or in the subsequent years remains relatively low.