Ten common questions for cross-border families: money, residency and reporting across mainland China, Hong Kong and Singapore

A cross-border family is one whose members, assets, income or businesses are spread across two or more jurisdictions. On this site, it mainly means a family based in mainland China whose assets or residency extend to Hong Kong and Singapore. The difficulty for these families is usually not which product to choose but how the rules of the three places fit together: whether money can leave the mainland lawfully, how its source is documented, where the family is tax resident, where information is exchanged to, and whose law applies on death or incapacity. The ten questions below are each labelled with the jurisdictions they concern. This page describes rules only and does not provide any route for moving money offshore.

Moving money and source of funds (Questions 1–3)

1. What rules now govern outbound investment by mainland resident individuals

Under the State Council Provisions on Outbound Investment (State Council Decree No. 837, published 5 May 2026, in force from 1 July 2026), Article 2 defines investors to include enterprises, other organisations and resident individuals in mainland China. Article 12 requires investors to complete truthfully any approval or filing, information reporting, cross-border fund registration or other formalities required by law. Article 33 provides that the specific rules for outbound investment by resident individuals and others are to be issued by the State Council's investment and commerce authorities. As at October 2026, the latest rules published by the competent authorities apply. Jurisdiction: mainland China.

2. Can foreign exchange bought by an individual be used to buy overseas life insurance

The national rule is the Administrative Measures on Individual Foreign Exchange (PBOC Order No. 3 [2006], in force from 1 February 2007). Article 3 provides that individual capital-account foreign exchange business is managed according to the convertibility process; Article 9 provides that individual foreign exchange purchases are subject to an annual quota, with capital-account items handled under Chapter 3. Among the permitted items listed in Chapter 3, the only life insurance item is "paying foreign-currency life insurance premiums to domestic insurers" (Article 18); buying overseas life insurance is not included. SAFE's catalogue of regulations in force (as at 30 June 2026) still lists the Measures and their implementing rules as basic regulations. Branch-level guidance is more direct: the SAFE Xiamen Branch's Tips on Individual Foreign Exchange Services (October 2021) states that foreign exchange purchased by domestic individuals may not be used for capital-account items not yet opened up, such as buying property abroad, securities investment, or buying life insurance and investment-type or dividend-paying insurance. Individuals must complete the Individual Foreign Exchange Purchase Application truthfully. SAFE's current rules prevail. Jurisdiction: mainland China.

3. What evidence of source of funds and source of wealth is needed

When opening an account or accepting money, Singapore banks, insurers and trust companies generally want to understand the source of funds (which account the money comes from and why) and the source of wealth (how the client's overall wealth was built up). The Guidelines to MAS Notice 626 describe source of wealth as the origin of the client's entire body of assets; acceptable evidence includes salary records and tax returns, bank statements, audited financial statements of controlled companies, share sale documents, trust deeds and gift documents. Where the client or beneficial owner is a politically exposed person, the bank must also obtain senior management approval and step up ongoing monitoring. After the 2023 money laundering case, Singapore's Inter-Ministerial Committee published a report on 4 October 2024 to strengthen the anti-money laundering framework further. Jurisdiction: Singapore.

Tax reporting and information exchange (Questions 4–5)

4. Must a mainland tax resident report foreign income

Yes. The Individual Income Tax Law treats a person as a resident individual if they have a domicile in mainland China or stay there for an aggregate of 183 days or more in a tax year; domicile means habitual residence in China by reason of household registration, family or economic ties. Resident individuals are taxed on income from inside and outside China. Under MOF and STA Announcement No. 3 of 2020, foreign income must be reported and tax paid between 1 March and 30 June of the year after the income is received. Singapore generally does not tax individuals on foreign income remitted into Singapore (IRAS), but this does not affect the mainland reporting obligation. For how residence is determined, see Residency and tax residence. Jurisdictions: mainland China / Singapore.

5. Is account information in Hong Kong and Singapore exchanged with the mainland

Yes. All three are CRS participating jurisdictions. Hong Kong began automatic exchange on 30 June 2016, and its reportable jurisdictions include mainland China (from the 2018 batch); Singapore has exchanged information since September 2018; and the mainland's Administrative Measures on Due Diligence for Non-resident Financial Account Tax Information took effect on 1 July 2017. Financial institutions report according to the account holder's tax residence, and cash-value insurance policies and the controlling persons of trusts and companies are all in scope (see CRS and cross-border information exchange). Being reported does not mean tax is owed; what matters is whether the information matches what the person has declared. Jurisdictions: mainland China / Hong Kong / Singapore.

Dividing roles between two hubs and family spending (Questions 6–7)

6. How do Hong Kong and Singapore divide the work

Neither levies estate duty (Hong Kong abolished it from 11 February 2006; Singapore no longer levies it for deaths on or after 15 February 2008), and both are CRS participating jurisdictions. The main differences lie in residency routes and market connections. On residency, Hong Kong's New Capital Investment Entrant Scheme requires net assets of at least HK$30 million held continuously for the six months before application, and an investment of at least HK$30 million in permissible investment assets (InvestHK); the conditions of Singapore's GIP are covered in Residency and tax residence. Opinion: Hong Kong connects more closely with mainland capital markets, and Singapore more with ASEAN and international capital. Many families use both, dividing roles by purpose rather than by which place is "better". Jurisdictions: Hong Kong / Singapore.

7. With children studying abroad and parents in the mainland, where should assets be held for ease of use

Allocate first by the currency, timing and user of each expense, then decide where to hold the money. Set aside tuition and living costs in the currency of the study destination, plan for the parents' retirement and medical costs as mainland expenses, and only then consider multi-currency allocation for long-term growth money. Singapore deposit insurance covers only Singapore-dollar deposits and is capped; foreign-currency deposits are not covered (SDIC; for the cap, see The wealth tool landscape). Where assets are held does not change the CRS reporting jurisdiction, nor a mainland resident's obligation to report foreign income. For how to divide money by task, see Asset allocation framework. Jurisdictions: Singapore / mainland China.

Choice of law and businesses going overseas (Questions 8–9)

8. Whose law applies to cross-border marriage and succession

Each jurisdiction has its own conflict-of-laws rules. Under Article 31 of the mainland's Law on the Application of Laws to Foreign-related Civil Relations, statutory succession is governed by the law of the deceased's habitual residence at death, but statutory succession to immovable property is governed by the law of the place where the property is located. Under Article 32, a will is formally valid if it complies with the law of the testator's habitual residence or nationality, either when the will was made or at death, or with the law of the place where the will was made. Singapore and Hong Kong deal with assets located there under their own law. Ownership and division of matrimonial property may likewise lead to different answers in different jurisdictions. In practice, families often make separate wills for each place where assets are held, drafted to work together (see Succession and family governance). Jurisdictions: mainland China / Hong Kong / Singapore.

9. How does setting up a Singapore company for an expanding business relate to personal wealth planning

The two should be designed separately and checked against each other. At business level, Decree No. 837 also applies to outbound investment by domestic enterprises, and any approval or filing and cross-border fund registration must be completed as required by law; Singapore's corporate income tax rate is 17% (IRAS). At personal level, who holds the shares, where dividends flow and whether the individual remains a mainland tax resident determine the individual's reporting obligations. Common risks are mixing company accounts with family spending, nominee shareholdings that do not match the actual controller, and personal guarantees left out of the family's risk assessment. The "five maps" in the Asset allocation framework can be used to check everything against one set of facts. Jurisdictions: mainland China / Singapore.

When professional advice is essential (Question 10)

10. When must you engage a lawyer and a tax adviser

If any of the following applies, it is advisable to obtain written professional advice before acting:

The rules for cross-border families keep changing. This page is current as at 23 October 2026; for questions on tax, foreign exchange and CRS, please obtain professional advice in the relevant jurisdiction. If you would like this interpreted for your own situation, you can register your needs through the contact details on this site.