We conducted some research on CRS 2.0 and would like to share a few observations with everyone.

Let’s say the conclusion upfront: at this moment, we are at least 1.5 years away (and even 2–3 years) from the matter of taxing crypto trading on exchanges.

First, there is an international organization called the OECD. The OECD designed the CRS 1.0 regime.

At its core, CRS is only a way of reporting. It itself does not involve tax.

Based on the internationally standardized reporting approach set by CRS, each country then designs how to collect tax according to its own situation. Therefore, CRS ≠ paying taxes.

For example, in Singapore, retail investors trading crypto on their own typically don’t pay capital gains tax in the first place. So when CRS 2.0 comes into effect (Singapore has also signed on), filing is required—however, there is still no tax.

Many Chinese media haven’t quite gotten this point: what will affect people who trade cryptocurrencies more in this round is another standard under the OECD called CARF, which stands for Crypto Asset Reporting Framework.

CARF is essentially a sibling of CRS 2.0.

Just from the full name, you can tell that this reporting system is specifically for cryptocurrencies.

Many people say vaguely that if this actually takes effect, they will withdraw their assets from exchanges to the blockchain.

The general idea is correct, but there are some misconceptions in how people implement it in practice.

If you wait until CARF takes effect in your tax jurisdiction before moving large amounts of assets on-chain, those on-chain addresses will be KYC-verified and reported, and even unknown external addresses may be treated as your own wallet.

Because CARF itself was developed after research specifically on cryptocurrencies, it wouldn’t leave such a loophole.

That is, if you want to exploit a bug using an on-chain withdrawal strategy, you still have to do it before it takes effect in your tax jurisdiction.

PS: Of course, we still recommend reporting and paying taxes truthfully in accordance with local laws and regulations.

For example, Hong Kong and Singapore start collecting data on January 1, 2027, and begin exchanging it in 2028.

But here’s the interesting part: mainland China joined CRS 1.0, yet it hasn’t been decided when it will join CRS 2.0.

Moreover, mainland China hasn’t even committed to joining CARF, because in mainland China, trading virtual currencies is subject to a prohibitive regulatory framework.

Overall, it can be broadly divided into three batches:

The first batch took effect in 2026 already, for example the EU, the UK, Japan and South Korea, Switzerland, and the Cayman Islands;

The second batch will take effect in 2027, for example Hong Kong and Singapore;

Only the third batch might include mainland China.

So we believe that at least another 1.5 years remains before formal rollout—if things move more slowly, it could be 2 to 3 years. Of course, if you live long-term in jurisdictions like the UK or Japan that have already clearly published timelines, then you need to pay attention to earlier time points.

Overall, the current time window is still quite ample.

Also, thanks to DeFi having developed for so many years, it’s now relatively mature—so it isn’t too hard for users to move from exchanges to DeFi.

The difficulty is that you need to complete it within an appropriate time window, based on your own tax jurisdiction.