China, the world's second largest economy, continues on its path to internationalising its markets with foreign companies. While capital flows in and out of China are controlled, China has launched a number of Free Trade Zones, including in Shanghai, which offer less controlled open foreign currency exchange and tax breaks to certain industries.
Despite capital controls, China has the 12th largest foreign exchange market in the world, and its bond market is the third largest in the world, with a diverse range of public and private debt. Foreigners can invest in it through the Qualified Foreign Institutional Investor Program and the RMB Qualified Foreign Institutional Investor Program.
China is more popular as a location for Shared Service Centres rather than Regional Treasury Centres. Currency controls in and out of China make it advantageous for companies with significant operations in China to also have a treasury operations base in the country. The setting up of the Cross-border Interbank Payment System (CIPS), which connects with SWIFT, has made cross-border payments in renminbi faster and easier for businesses.
China's banking sector is dominated by four large state-owned commercial banks. Foreign banks have a growing presence in the country, but they account for only a small percentage of the sector's assets.
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Corporate Treasury in China
China, the world's second largest economy, continues on its path to internationalising its markets to foreign companies. Here, we highlight some of the key benefits relevant to treasury and cash management in China.
Financial Market Development
- The World Economic Forum ranks China 48th in the world for financial market development in The Global Competitiveness Report 2017-2018.
- The report ranks China 82nd for the soundness of its banks, with access to financing seen as the most challenging aspect of doing business in the country.
- China has the largest banking sector in the world. It is dominated by five large state-owned banks.
- While capital flows in and out of China are controlled, China has launched a number of Free Trade Zones, including in Shanghai, which permit less controlled foreign-currency exchange and offer tax breaks to certain industries.
- China is continuing to internationalise the renminbi, which was added to the IMF's Special Drawing Rights basket in October 2016.
Sophistication of Banking Systems
- China's banking sector is dominated by five large state-owned commercial banks. In addition, there are more than 1,000 rural and city commercial banks. Foreign banks have a growing presence in the country, but they account for only a small percentage of the sector's assets.
- Despite capital controls, China has the 12th largest foreign exchange market in the world, accounting for 1.1% of global turnover (Bank for International Settlements triennial global survey 2016).
- China's bond market is the third-largest in the world, valued at around USD12 trillion. It has a diverse range of public and private debt. Foreigners can invest in it through the Qualified Foreign Institutional Investor Program and the RMB Qualified Foreign Institutional Investor Program, although they currently hold less than 2% of the debt.
- The setting up of the Cross-border Interbank Payment System (CIPS), which connects with SWIFT, has made cross-border payments in renminbi faster and easier. A second phase of the scheme has been launched extending its operating hours and enabling more foreign direct participants.
- China is in the process of reforming financial regulation, merging the China Banking Regulatory Commission (CBRC) and the China Insurance Regulatory Commission. The central bank, the People's Bank of China (PBOC), will be given an enhanced regulatory role, including creating new laws and regulations, as well as maintaining financial market stability.
- The State Administration of Foreign Exchange (SAFE) regulates foreign-exchange activity and manages the state foreign-exchange reserves.
- Regulations differ in the Free Trade Zones, and may also vary from city to city.
- The corporate income tax rate is 25%.
- Resident enterprises are taxed on their worldwide income whilst non-resident enterprises are taxed on all China-sourced income.
- A lower corporate income tax rate of 10%, 15% or 20% is available under certain circumstance, including for small-to-medium enterprises (if certain conditions are met) and enterprises with new/ high-technology status.
- Value Added Tax (VAT) is charged at 6%, 10% or 16% depending on the type of goods or services (as of 1 May 2018). Some goods and services are zero-rated.
- Withholding tax is charged at 10% on interest and dividends. For dividends, with effect from 1 January 2017, companies can defer withholding tax on dividends distributed to foreign investors by reinvesting into "encouraged investment projects" in China and meeting certain other conditions. As for interest, in addition to withholding tax, a standard VAT of 6% is imposed. Rates range from 0% to 15% for countries where a tax treaty is in place and a non-resident can provide a Certificate of Residence.
- Interest income and capital gains are treated as ordinary income. Interest expenses that are used for business purposes are generally tax-deductible although excessive interest expense from related party financing will not be tax deductible. Generally, if the debt-to-equity ratio exceeds 3:1, the excess portion will not be tax deductible. Certain companies such as banks, financial holding companies, insurance companies, securities companies, etc. are not subject to the ratio.
- Unrealised exchange gains are generally taxable.
- Stamp tax at ad valorem basis of between 0.005% and 0.1% is charged on various types of contracts and documents.
- Foreign tax credits can be claimed by tax-resident enterprises for foreign income tax paid overseas on income derived outside of China, subject to fulfilment of certain criteria prescribed.
- China has tax treaties with more than 100 countries and territories.
- China is a signatory to the Organisation for Economic Co-operation and Development's Multilateral Competent Authority Agreement, through which information is exchanged between tax administrations, to provide a single, global picture on some key indicators of economic activity within multinational enterprises.
Benefits for Regional Treasury Operations in China
China is more popular as a location for shared service centres (SSCs), rather than regional treasury centres (RTCs). Companies with a strong China focus are more likely to base their treasury centres in Hong Kong or Singapore.
- Currency controls in and out of China have made it advantageous for companies with significant operations in China to have a treasury operations base in the country.
- The People's Bank of China and State Administration of Foreign Exchange have introduced a number of pilot schemes that relax foreign exchange rules for foreign-owned companies, including allowing cross-border RMB lending and cross-border sweeping of RMB and foreign currencies.
- China has stated that it wants Shanghai to be an international financial centre by 2020; market infrastructure and access to treasury professionals in the city is improving.
- Domestic payments require Chinese characters in some fields, so treasurers must ensure their enterprise resource planning (ERP) systems can support this.
Regulatory Considerations for Payments
- China recently announced a clamp down on entrustment loans, the vehicle through which intercompany lending must be done in most circumstances.
- Notional pooling is not allowed in China.
- Netting is closely monitored and companies must provide monthly balance of payments reporting on an original transactions basis. Netting reports must also be submitted to local tax bureaux.
- A number of schemes exist for cross-border sweeping, including RMB outbound lending and a scheme enabling companies to link their onshore and offshore cash pools, subject to controls on inflow and outflow of funds.
- Different regulations affect payments and collections, with supporting documentation requirements differing for payments for services and trade, and for current accounts and capital accounts.
- There are five main commercial banks in China: Industrial & Commercial Bank of China, China Construction Bank, Bank of China, Agricultural Bank of China and Bank of Communications. These banks are state controlled, and they have majority government ownership and lead China's banking sector.
- In addition, there are 859 rural commercial banks, 12 joint-stock commercial banks and 133 city commercial banks, among other provincial financial institutions.
- The China Banking Regulatory Commission launched a pilot programme to introduce private banks to its banking sector, and in 2014 and 2015, ten applications were approved, with a further five in 2016. These banks have a focus on providing lending facilities to small and medium-sized enterprises.
- Foreign banks (145) are active, although they make up only a small percentage of banking sector assets. In terms of regulation, they are treated as domestic banks. They may offer renminbi-denominated products and branches of foreign banks may offer time deposits for residents with RMB 1 million or more per transaction.
- Second-tier joint stock banks were originally wholly government owned, but these are now jointly owned by the government and commercial entities, with the government holding majority ownership.
- The PBOC’s capital and currency controls have stemmed the depreciation of the renminbi and resulted in an increase in foreign exchange reserves.
- Residents may hold foreign exchange and RMB accounts domestically. However, residents are required to gain State Administration for Foreign Exchange (SAFE) approval to open foreign exchange accounts overseas, excluding export enterprises using foreign exchange accounts for export transactions whereby only registration with SAFE is required.
- Non-residents may hold foreign exchange and RMB currency accounts domestically and RMB accounts overseas. To open a bank account, strict local regulations require it to be carried out in person with extensive supporting documentation, the company's financial chop and the chop of the legal representative; SAFE approval is required to open foreign exchange accounts overseas. A special account is required in order to receive foreign currency from overseas for the purpose of clearing cross-border loans.
Onshore Foreign Currency
Offshore Foreign Currency
(no permanent establishment)
1. Only Shanghai registered companies can apply for foreign entity RMB accounts for their overseas investments subject to Ministry of Commerce and PBOC approval.
2. Chinese resident companies may open a foreign currency account offshore for specific trading or project investment purposes subject to SAFE approval.
3. Foreign entities can open NRA CNY accounts with Chinese banks or open NRA CNH accounts with overseas banks, with no PBOC approval required.
4. Foreign entities can open RMB denominated accounts outside China, such as CNH accounts in Hong Kong. RMB can also be held in other locations such as Singapore or London.
There are several types of domestic currency (RMB) accounts. The two main ones where transactions can be readily used are:
Basic account: Used specifically for payroll and cash withdrawals; one account per legal entity.
General account: Used for payments and receipts (cannot be used for payroll or cash withdrawals); unlimited number of accounts per legal.
|Account type|| |
The primary account maintained by a company used for funds transfer, settlement, payroll, and cash deposits/withdrawals. The opening of a basic account is subject to PBOC approval where the company is registered.
A company is allowed to maintain only one basic account and it should be opened with a bank located in the same city where the entity is registered. This is an important account and care should be taken in selecting a quality bank near the company's offices.
|The company can maintain any number of general accounts with multiple banks to meet additional business needs or for special purposes set out in the rules and regulations in China. May not be used for cash withdrawals or payroll. Tax accounts are a type of a general account used to pay local and provincial taxes.|| |
Can be used for the same type of payments and receipts as basic accounts, but not for payroll or cash withdrawals. There is no restriction in the location and number of general accounts. Tax accounts can only be opened with those banks that have an established link with the local tax bureau, and may not require the opening of an additional account.
- There are foreign currency accounts available in most of the major currencies including USD, EUR, HKD, JPY, SGD, AUD, GBP, NZD, and CHF, and they fall into three broad categories of use:
This account is established by the company to receive and disburse the foreign currency that is injected into China as capital for the enterprise.
Chinese entities are permitted to have this account in the RMB.
Registration with SAFE is required and expenditure from this account is subject to SAFE approval. Additional accounts may be opened thereafer without SAFE pre-approval. Holding multiple accounts is possible.
This is an important account and care should be taken in selecting a quality bank. Proximity to the company's offices is not required.
Companies can choose to establish a RMB capital account instead of a USD capital account if they want to manage their FX exposure directly.
|This account is used for day-to-day operational needs that are transacted in foreign currencies, such as import and export transactions. It can also be used to pay and receive funds for services rendered under a service contract agreement.|| |
There is no restriction in terms of the number of settlement accounts, aggregate balances, and the location where the settlement account is maintained. Supporting the documentation is required for third party payments.
|Loan||This account is used for any foreign currency borrowing from both banks and overseas shareholders.||Pre-registration with SAFE is required for each foreign debt contract. After registration, accounts may be opened without pre-approval.|
Legal and Regulatory
- The People's Bank of China is China's central bank and it is controlled by the State Council.
- After China’s stock market turbulence in 2015, measures have been put in place to tighten regulation of the financial sector. The China Banking and Insurance Regulatory Commission was established in 2018 under the auspices of the PBOC, a consolidation of the China Banking Regulatory Commission and the China Insurance Regulatory Commission. Its role is to manage and limit financial risk and supervise the development of the insurance and financial sectors.
- The Financial Stability and Development Committee, under the State Council, was launched in 2017 to coordinate overall strategy for the financial sector and formulate policy at a local government and high level.
- The PBOC set up a financial technology (fintech) committee in 2017 to oversee developments in fintech and examine the effects on monetary policy and the financial sector. In parallel, the PBOC has increased the use of regulatory technology (regtech) to boost its capabilities in managing financial risk.
Definitions for resident and non-resident status, and for enterprises incorporated in China and those managed or controlled in China, are in the Enterprise Income Tax Law (EITL).
SAFE is responsible for all foreign exchange activity of residents and non-residents.
China has anti-money laundering legislation in place, is a member of various international anti-money laundering groups and has a financial intelligence unit at the PBOC.
Repatriating funds from China is subject to a strict process of accountability with SAFE, whereby relevant transaction documents and a detailed audit must be carried out and filed before the funds can be released.
The Renminbi Qualified Foreign Institutional Investor (RQFII) scheme allows overseas investors to access offshore renminbi deposits to invest in China's securities markets through selected Chinese financial institutions based in Hong Kong. As part of the initiative to further liberalise China’s capital markets, RQFII has been made less restrictive and Hong Kong’s quota for the scheme has increased to RMB 500 billion.
Free Trade Zones are specially designated areas that are free from customs intervention and where goods can be manufactured, re-exported and traded. The first FTZs were Shanghai, Tianjin, Shenzhen and Fujian, however, more have been added, to bring the total to 11.
(China National Advanced Payment System)
Divided into 2 types:
CNAPS–HVPS (High Value Payment System)
For high value (more than RMB 50,000) and urgent interbank transfers
CNAPS–BEPS (Bulk Entry Payment System)
For low value (less than RMB 50,000) electronic credits or debits
(City Clearing Processing Center)
In-city clearing system
(China Domestic Foreign Currency Payment System)
Processes foreign domestic currency payments
(Cheque Imaging System)
National electronic cheque clearing house
(China International Payment System)
(Internet Banking Payment System)
Interbank credit and debit transfer system
(Treasury Information Processing System)
Electronic tax payment system
- Transactions are settled via CNAPS–HVPS or CNAPS–BEPS, depending on the value and urgency of the payment.
- Domestic payments require Chinese characters to be used in specific fields, therefore, the corporate ERP systems must be able to support this qualification.
Direct Debits (auto debits)
- Transactions are settled via CNAPS–BEPS, whereby dated debits are cleared the next day and pre-authorised debits are cleared the same day.
- A common form of payment. There were 6.35 billion cards in circulation at the end of 2017, of which 58.28 million were debit cards and 520 million were credit cards.
- China UnionPay (CUP) is the most common card used in China, although Visa-branded cards are being increasingly adopted by local banks.
- Chip-embedded payment cards in the form of IC-based bank cards are being promoted by the PBOC in a move away from renminbi-denominated magnetic cards.
- Transactions are processed and cleared via CNAPS–BEPS same day or next day.
- ATM and EFTPOS networks are operated by CUP. Coverage is increasing in line with the use of payment cards.
- Fintech has been widely integrated across China’s banking industry, being adopted prominently in areas such as online lending, consumer finance, online money market funds, online insurance, personal financial management and online brokerage.
- Mobile banking has become a rapidly increasing mode of banking by the big banks and third-party providers, offering a wide variety of banking services online. The most popular mobile banking apps are offered by China Construction Bank, Industrial and Commercial Bank of China and a smaller player, Ping An Pocket Bank.
- Mobile wallet use is a major payment medium, with China having the largest mobile payment market in the world (in terms of value of transactions). Alibaba’s Alipay and Tencent’s WeChat Pay are the two dominant mobile payment apps. Both offer payment and transfer facilities, whether online or offline using QR codes and PINs, and target small and medium-sized enterprises
- Online payments have outstripped the use of payment cards, with the three dominant players being Alipay, UnionPay and Tencent Finance.
- Mobile banking and online lending are the two most prominent sectors in China’s fintech industry.
- The Bank of Communications launched a mobile credit card in 2017, the first Chinese bank to make a credit card’s features completely digital.
- A few Chinese banks have introduced facial recognition technology at ATMs in cities across China, doing away with the necessity to carry payment cards and improving financial security.
- Cryptocurrency exchanges are currently banned in China and the PBOC has declared initial coin offerings to be illegal.
- However, the central bank has also announced plans to develop a ‘sovereign digital currency’ and acknowledged the potential for this monetary system.
Cash, Cheques and Money Orders
- The Cashless Alliance, a collaboration with the United Nations Environmental Agency and 16 other partners, was set up to develop financial mechanisms to eliminate the use of physical payment cards and cash.
- The overwhelming growth of cashless systems has triggered a directive from the PBOC for vendors not to discriminate or refuse cash payments. Recent surveys rank cash as the fifth most popular form of payment in China, behind various mobile, credit and debit systems.
- Cheques are a mode of payment used for retail and commercial payments. Cheques have to be validated with the company stamp and a handwritten signature; this medium of payment is not often used for personal use.
- Valid only for 10 days and limited to a written maximum value of RMB 500,000.
- Inter-city cheques are converted into electronic form and then cleared through CIS, with final settlement done via CNAPS–BEPS. Payments are usually cleared within 48 hours. Local cheques are cleared by local clearing houses.
- Money orders are available in China through vendors such as Western Union and MoneyGram. Money can be sent domestically or internationally, either online or in person.
A short history of the QR code in China and why Southeast Asia is next
The all-pervasive QR code has redefined what it means to make purchases and sales in the country, and it is driving a mobile payment trend that is crippling the growth of traditional payment systems like ATMs and even POS (point of sale) terminals. Overseas, Chinese QR code payment service providers are looking to set off another wave of disruption in cash-based economies.
Read more about the development here.
China moves to block online payments for cryptocurrency on overseas exchanges
China is tightening regulations on cryptocurrency. According to local media reports, the National Internet Finance Association of China will regulate 124 cryptocurrency trading platforms whose servers are all overseas, inspect and shut down domestic initial coin offering or trading platforms, WeChat accounts, and limit their access to payment.
Read more about the development here.
This Market Profile is brought to you by DBS. Get in touch with us for further insights on doing treasury in China and take advantage of our innovative solutions to empower your business. Click here to find out more.
Sources: The World Economic Forum The Global Competitiveness Report 2017-2018; IMF; Bank for International Settlements; Bloomberg; People's Bank of China; PwC; OECD; Association for Finance Professionals
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