Free Trade Accounts (FTAs) Background The Circular on the Implementation Rules on Separate Accounting Business in the China (Shanghai) Pilot Free Trade Zone (Interim) and the Rules for the Prudential Management of Risks Relating to Separate Accounting Business in the China (Shanghai) Pilot Free Trade Zone (Interim) (Circular 46) was released on May 21, 2014. The circular stated that companies operating in the China (Shanghai) Pilot Free Trade Zone (hereinafter referred to as the “Shanghai FTZ”) would be allowed to open free trade accounts (hereinafter referred to as “FTAs”) within the Shanghai FTZ to facilitate the free movement of funds with outside mainland China. Outline FTAs are new bank accounts established in order to satisfy both further liberalization of the “first tier (the boundary between the Shanghai FTZ and overseas)” and the safe, effective control of the “second tier (the boundary between the Shanghai FTZ and the rest of mainland China)” as part of financial reforms in the Shanghai FTZ. (The accounts can be used for both RMB and foreign currencies.) While funds can be freely transferred between FTAs and accounts outside mainland China, fund transfers between FTAs and accounts within mainland China are administered as cross-border transactions. [Free fund transfers] Outside the FTZ within mainland China Second tier Shanghai FTZ First tier Outside mainland China Fund transfers through FTAs FTA (Company A) Non-resident account (NRA) Account outside mainland China FTA (Company B) Funds can be freely transferred between accounts outside mainland China, non-resident accounts (NRAs) outside the FTZ within mainland China and other FTAs, based on receipt and payment instructions. [Cross-border transactions] Outside the FTZ within mainland China Ordinary settlement account (outside the FTZ) Second tier Shanghai FTZ First tier Outside mainland China FTA (Company A) Account outside mainland China Non-resident account (NRA) Ordinary settlement account (within the FTZ) Fund transfers between FTAs and ordinary bank settlement accounts on mainland China (including the FTZ) are administered as cross-border transactions, and thus the confirmation by a bank is required (including transfers between accounts under the same name). 1 Copyright (c) Mizuho Bank, Ltd. All Rights Reserved. Offshore financing through FTAs Background The Circular on the Implementation Rules for Macro-prudential Management of Offshore Financing and Cross-border Capital Flows for Separate Accounting Business in the China (Shanghai) Pilot Free Trade Zone (Interim) (Circular 8) was released on February 12, 2015. The circular stated that companies operating in the Shanghai FTZ would be allowed to use FTAs to borrow offshore loans (foreign debt) of up to twice the company’s capital (paid-in capital + capital reserves) from outside mainland China. Outline In addition to the traditional methods of obtaining offshore financing, companies in the Shanghai FTZ can choose one of the following three options. (1) Foreign debt administration based on the borrowing gap (traditional method) (2) Administration of offshore RMB-denominated loans based on paid-in capital (launched in February 2014) (3) Administration using FTAs (this example) In principle, no changes are admissible after a company has selected which of (1) to (3) to use. If the company has to change the selection for a rational reason, they need to file an application, via their settlement bank, to the PBOC Shanghai Head Office. Only one change is permitted. Within mainland China Outside mainland China Financing scheme Account outside mainland China FTA Shanghai FTZ Financing Repayments 2 Copyright (c) Mizuho Bank, Ltd. All Rights Reserved. Foreign debt financing models: A comparison (1) Borrowing gap* model (traditional method) Foreign companies located on Target companies mainland China (including both within and outside the FTZ) (2) Paid-in capital model (3) Macro-prudential management model Companies within the FTZ (Chinese or foreign) Companies within the FTZ with an FTA (Chinese or foreign) Target currency RMB/foreign currencies RMB RMB/foreign currencies Financing account Special account (RMB/foreign currency) Special RMB account (a financial institution in the Shanghai area) FTA (opened at a financial institution located within the Shanghai FTZ) Fund usage Usage based on actual demand Usage based on actual demand Usage based on actual demand Loan period Unrestricted One year and longer (including one year) Unrestricted Within the borrowing gap Paid-in capital × 1 × macroprudential adjustment parameter*3 Capital*1 × offshore borrowing leverage ratio*2 × macro-prudential adjustment parameter*3 Upper limit to financing Balance management by multiplying the amount by the following risk factors*4 <RMB> Accrual management for shortterm and medium/long-term (quota not restored) Management of debt quota <Foreign currencies> Short-term: Balance management (quota restored after repayment) Medium/long-term: Accrual management [Balance within the credit limit] = Offshore financing balance × (1) period risk conversion factor × (2) currency type risk conversion factor × (3) categorization risk conversion factor • Foreign currency trade finance (× 20%) • Including off balance financing Balance management *1: Capital = [paid-in capital + capital reserves] *2: The leverage ratio differs for each company. For companies within the Shanghai FTZ, the ratio is “2.” *3: The parameter is initially set at “1.” *4: Type of risk and factor Type of risk (1) Period risk (2) Currency type risk (3) Categorization risk Risk category Medium/long-term loans Short-term loans RMB-denominated Foreign currency-denominated On balance financing Off balance financing Factor 1 1.5 1 1.5 1 0.2, 0.5 (* For details about the borrowing gap, please consult the separately listed “RMB-denominated Investment & Capital Increases.”) If you have any inquiries, please contact the branch in charge of your account or any local Mizuho branch. Disclaimer & Confidentiality 1. Purpose: This publication is compiled solely for the purpose of providing readers with information and is in no way meant to encourage readers to buy or sell financial instruments. 2. Legal, accounting and tax advice: The information contained herein does not incorporate advice on legal, accounting or tax issues. 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