Multilateral Convention on Mutual Administrative Assistance in Tax Matters
Published: July 26, 2026
Sources & Verification
Primary Source
State Taxation Administration (SAT) — Official document ↗
CPG Analysis
AI-assisted summary of the official source linked above, pending human review.
Verification
AI-assisted summary · generated Oct 21, 2026 · pending human review
This summary was generated by AI from the linked official source. It has not been reviewed line-by-line by a human editor.
⚡ Impact at a Glance
Who is affected
Tax directors, CFOs and compliance heads at multinational groups with China entities; cross-border treasury, transfer pricing and M&A teams; and financial institutions handling CRS and FATCA-style account reporting.
Cities / Agencies
Nationwide · State Taxation Administration (SAT)
What to do now
Confirm that your China entity's intercompany pricing, offshore structures and account-reporting data would withstand a foreign information request routed through the State Taxation Administration.
Source & verification
STA · AI-assisted summary · generated Oct 21, 2026 · pending human review
What to watch next
STA: implementing announcements and guidance on exchange-of-information requests, CRS/non-resident financial account reporting rules and competent-authority agreements; MOF: instruments of ratification, accession and any reservations or declarations; OECD: updated list of participating jurisdictions, CRS implementation status and peer-review reports; STA/MOF: updates to the catalogue of taxes covered and any opt-in to indirect taxes
Executive Summary
This is the text of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the global framework through which tax authorities exchange information, conduct joint audits, and help each other collect tax claims. For companies with cross-border operations, it means Chinese tax authorities can obtain banking, ownership and accounting data from more than 100 partner jurisdictions — and foreign authorities can obtain the same from China. The posting is a reference publication of the treaty rather than a new rule, so it changes no compliance deadline by itself.
Key Points
The Convention authorises three forms of information exchange — on request, spontaneously, and automatically — covering taxes of every kind imposed by a Party, including income, capital gains, VAT and other indirect taxes.
Parties may also conduct simultaneous tax examinations, allow foreign tax officials to be present during examinations in their territory, and assist in the recovery of foreign tax claims and the service of documents.
Taxpayers gain procedural protections: requested states must notify the person concerned before supplying information, and any exchanged data is subject to strict confidentiality rules and limits on onward use.
A Party may refuse assistance where it would breach its own law or public policy, or where the request is purely a 'fishing expedition' — but bank secrecy cannot be invoked as grounds to refuse.
The Convention is the legal backbone for automatic exchange frameworks such as CRS, meaning financial institutions' account data on Chinese tax residents flows to the competent authority and outward to partner jurisdictions.
China is a Party to the Convention and has made reservations on certain forms of assistance, so the scope of what China will actually provide or request is narrower than the Convention's full text.
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📝 Update History
July 27, 2026
Minor updates, no substantive change.
August 19, 2026
The new version adds the amendments from the 2010 Protocol, which broadens the scope of mutual administrative assistance (e.g., to cover tax crimes without the dual criminality requirement) and includes
August 20, 2026
Minor updates, no substantive change.
October 13, 2026
Policy content updated; see official source for details.
October 15, 2026
Policy content updated; see official source for details.
October 18, 2026
Policy content updated; see official source for details.
October 21, 2026
Minor updates, no substantive change.