Offshore Trust Watch | SHEIN-W (00625.HK) Falls 4.11% as Controlling Shareholder Xu Yangtian Controls About 49.9% of Votes via Cayman Trust

On October 15, 2026, the cross-border e-commerce theme saw volatile pullbacks, and SHEIN-W (00625.HK) traded lower. As of 15:33, the company was quoted at HKD 36.360, down 4.11%.

It is understood that SHEIN-W (00625.HK) listed on the Main Board of HKEX on September 1, 2026 at an offer price of HKD 48.56, offering about 280 million Class B shares globally and raising gross proceeds of about HKD 13.6 billion. The listing introduced seven cornerstone investors, including Boyu Capital, Tiger Global and General Atlantic, which subscribed for about 61.9 million shares, or about HKD 3 billion in aggregate, representing about 22.1% of the global offering; the shares held by these cornerstone investors are subject to six-month lock-up periods expiring in early March 2027.

In terms of shareholding structure, company founder, Chairman of the Board and Chief Executive Officer Xu Yangtian holds and controls 798,973,148 Class A shares and 487,090,102 Class B shares, representing about 30.3% of the total issued shares, and is entitled to exercise about 49.9% of the votes; Miao Miao, Gu Xiaoqing and Ren Xiaoqing hold about 14.9%, 12.6% and 12.6% of the votes respectively, with the four together controlling about 90%.

It is understood that SHEIN's shareholding structure also involves offshore trusts. According to the listing documents and the interim report, Xu Yangtian is the settlor of a discretionary trust established under the laws of the Cayman Islands, with himself and his family members as beneficiaries; his holding chain runs from the Cayman trust to XYT Holdings Limited (British Virgin Islands) to Apex Sight Holdings Limited and then to the company's Class A and Class B shares, with Xu Yangtian serving as the sole director of Apex Sight. He holds about 30.3% of the shares through this structure, meaning that portion of his interests falls within the scope of the offshore trust. Miao Miao, Gu Xiaoqing and Ren Xiaoqing are each also the settlor of a discretionary trust, holding interests through six intermediate vehicles — Color Park Holdings Limited, Floral Field Holdings Limited, GXQ Holdings Limited, MM Style Limited, RXQ Holdings Limited and Upright Victory Holdings Limited — and the four together control about 90% of the votes. The names of these trusts, their trustees, protectors and settlement dates have not been disclosed.

In addition, SHEIN-W was fast-tracked into the Hang Seng Composite Index on September 15, but under the Stock Connect rules a weighted-voting-rights company must be listed for six months for first-time inclusion, and the company has yet to enter Stock Connect.

Regarding offshore trusts, on July 24, 2026, the Ministry of Finance and the State Taxation Administration jointly issued the Announcement on Matters Concerning Individual Income Tax on Offshore Trusts (Announcement No. 21 of 2026), bringing the entire life cycle of an offshore trust — establishment, existence and termination — into the individual income tax administration system, establishing three look-through points of establishment, existence and termination with a uniform 20% tax rate. The announcement specifies that during the existence of an offshore trust, income generated by an individual resident's offshore trust and by overseas entities held or controlled by that trust, whether actually distributed or not, is taxable to that individual resident, who must file and pay individual income tax on an annual basis. Article 6 of the announcement specifies that where, during the existence of an offshore trust of an individual resident, the individual resident becomes a non-resident individual, the taxable income is the balance after deducting the original value from the market value of the offshore trust's property on the day the individual becomes a non-resident, and individual income tax must be filed and paid. The 90-day supplementary filing window set by the announcement runs from July 24, 2026.

Guosen Securities noted in a research report that Announcement No. 21, through full-cycle taxation of "taxation upon establishment, look-through during existence and settlement upon exit", closes off the core path of deferring tax via offshore structures from the institutional level, leaving offshore trusts with little tax-planning value and confining their function to cross-border asset segregation and targeted succession; the cost of establishing and maintaining offshore trusts will rise substantially, structures built purely for tax saving will face cash-flow pressure, and the related wealth succession demand will shift structurally toward onshore vehicles.

On the operating side, the first interim results since listing, disclosed on September 28, show that in the first half of 2026 SHEIN recorded net revenue of USD 20.134 billion, up 1.0% year on year; net profit attributable to shareholders of USD 2.299 billion, up 111.7% year on year, mainly driven by non-operating items such as fair value changes of convertible redeemable preferred shares; adjusted net profit of USD 499 million, down 55.6% year on year; and operating profit of USD 493 million, down 52.9%. Total orders during the period rose 6.4% year on year to 549 million, active customers over the past 12 months reached 291 million, product revenue fell 1.9% year on year to USD 17.433 billion, and services revenue rose 24.9% year on year to USD 2.701 billion, with its share of net revenue rising to 12.7% in the second quarter. Cash reserves stood at USD 15.2 billion as at the end of June.

JPMorgan noted in a research report that SHEIN's share price has pulled back about 29% since its IPO, against a drop of about 5% in the Hang Seng Index over the same period, and that while the stock is under short-term pressure the trough is only temporary; amid US tariff adjustments and the Middle East conflict, the company continues to add new customers and grow orders, and as Middle East conflict-related costs recede and its European business shifts to local stocking, revenue is expected to stabilise from the fourth quarter, with profits expected to begin recovering in the first quarter of 2027.