The tax bureau called about my offshore account flagged via CRS — what should I do?
Don't panic, and don't lie. A CRS-triggered call is usually an interview (约谈), not a formal audit — yet. Your first job is to find out exactly what the bank reported about you, reconcile it against your own records, and then respond with facts. What you say in that first conversation matters: voluntary, accurate disclosure is treated very differently from getting caught hiding.
What CRS actually exchanges
| Data exchanged | What it is |
|---|---|
| Account balance | Year-end balance of the reportable account |
| Interest | Interest paid or credited |
| Dividends | Dividends paid or credited |
| Gross proceeds | From sale/redemption of financial assets |
Note what's missing: your cost basis, your other liabilities, and whether the money is even taxable. The bureau sees a number and asks questions — it's your job to supply the context.
How to prepare for the conversation
- Get your own records first. Pull the same year's bank statements for every offshore account before you go in.
- Reconcile. Match each CRS figure to a statement line. Flag anything you can't explain yet.
- Check your filings. Did you declare the overseas income on your annual settlement? If not, prepare a corrected filing (更正申报) — bringing it voluntarily changes the tone completely.
- Bring documentation for large balances: source of funds, transfer records, tax already paid elsewhere.
Voluntary disclosure vs. being caught
Coming forward with a corrected return is generally treated as a compliance fix — you pay the tax plus late-payment surcharges. Being caught after denying or ignoring the inquiry risks the case being classified as evasion (偷税), which carries heavier penalties and, in serious cases, criminal exposure. The call itself is your window: use it.
What not to say in the interview
- Don't guess numbers on the record ("I think it was around...") — say you'll verify and follow up in writing.
- Don't claim an account "isn't mine" if it is — the bank already reported your identity documents.
- Don't volunteer unrelated accounts or years unless asked — answer the question asked, completely and truthfully.
- Don't argue the law with the officer — if you disagree with an assessment, that's what objections and advisers are for.
The interview is fact-finding. Treat it like one: short, accurate answers, documents to back them, and written follow-up for anything you couldn't answer on the spot.
Frequently asked questions
Should I bring a tax adviser to the interview?
Yes, if the amounts are significant. An adviser keeps the conversation factual and stops you from speculating on the record.
What if the CRS data is wrong?
It happens — bank reporting errors exist. Bring the correct statements and ask the bureau to verify with the reporting institution. Don't just ignore it.
Will they check other years too?
Possibly. Once an account is on their radar, prior years' filings for the same income types may be reviewed. Reconcile more than just the year they asked about.
Sources
- http://www.tfcjtax.com/a/202606/1niacpn2nfvd8.shtml
- OECD Common Reporting Standard — reportable information (account balance, interest, dividends, gross proceeds)
- PRC Individual Income Tax Law — overseas income declaration obligations