China's New Individual Income Tax Policy for Offshore Trusts

China's Ministry of Finance and State Administration of Taxation (SAT) recently issued Announcement No. 21 of 2026, concerning a new individual income tax policy for offshore trusts. The SAT also issued Announcement No. 15 of 2026 on administrative matters concerning the new policy. Interpretation notes on Announcement No. 21 and Interpretation notes on Announcement No. 15 have also been issued.

The new policy essentially removes the ability to use offshore trusts to shield assets from t…