Large Transactions in the Cryptocurrency Sector: The Storm of Strict Regulation is Coming, What You Must Know!

Starting from December, large transactions in the cryptocurrency sector have been brought under strict regulatory scrutiny, with three scenarios becoming the focus of attention:

1. Cash transactions exceeding 50,000, regardless of which account, are under regulatory oversight.

2. Public account transfers that exceed 2 million will trigger the regulatory review mechanism.

3. Private account transfers are also not easy; overseas transactions exceeding 200,000 and domestic transactions exceeding 500,000 will be closely monitored.

At this point, someone may be calculating: if personal accounts are restricted, can't I just use WeChat or Alipay for payments? Don't be naive! The central bank clearly stated in the Yinfazhan [2018] No. 125 document that large transactions by non-bank payment institutions must also be reported. This means that large transactions on third-party payment platforms like WeChat and Alipay cannot escape scrutiny either. Even more critically, using these platforms for payments brings four major risks:

- Value-added tax risk: Using personal WeChat or Alipay for payments may cause confusion in value-added tax payments, laying a “time bomb” of tax risks.

- Corporate income tax risk: On one hand, collecting payment through personal WeChat or Alipay, even if tax declarations have been completed, may still be suspected of income concealment; on the other hand, if payments are made through these platforms, due to the difficulty in matching fund flows, goods flows, and invoice flows, it can easily be regarded as “tax evasion,” and may also result in the issuance of false invoices since it did not go through a public account, trapping the company in a tax quagmire.

- Personal income tax risk: If a company pays employee salaries through WeChat or Alipay, it may result in underreporting of personal income tax or intentional evasion, attracting the attention and investigation of tax authorities.

- Corporate management risk: Long-term collection of payments through personal WeChat or Alipay will blur the boundaries between corporate and personal assets. Once a company faces a debt crisis, shareholders will be required to bear unlimited joint liability, and personal assets may have to be used to repay company debts, exposing personal wealth to huge risks.

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