The China Offshore & Tax Policy Index: 2024-2025 Update
A comprehensive update documenting China’s offshore regulatory landscape, tax enforcement actions, and domestic incentive zones between 2024 and early 2026. Covers Controlled Foreign Corporation (CFC) rules targeting low-tax jurisdictions including BVI, Cayman Islands, and Bermuda. Details China’s “white list” of 12 countries exempt from CFC scrutiny. Profiles domestic tax incentive zones offering 15% corporate tax rates including Hainan Free Trade Port, Pilot Free Trade Zones (PFTZs), and Western Regions. Documents the expansion of MOFCOM’s Unreliable Entity List (UEL) with 14 foreign entities added in October 2025, primarily U.S. defense contractors. Includes ICIJ Offshore Leaks connections, regulatory trends, and summary statistics. Data sourced from PRC Ministry of Commerce, State Administration of Taxation, PwC, Lexology, and Reuters.
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