In order to support the effective use of foreign exchange funds by multinational corporations, since 2004, China has introduced policies on the centralized operation and management of foreign exchange funds of multinational corporations. The biggest advantage of multinational corporations 'centralized management of foreign exchange funds ("multinational corporations' foreign exchange funds pool") is that the amount of foreign debts of domestic enterprises in foreign exchange funds of multinational corporations can be used centrally, and between domestic member enterprises or between domestic member enterprises and overseas member enterprises Can exchange foreign exchange funds to achieve the purpose of reducing financial costs and improve the efficiency of the use of funds.

In order to further promote the trade and investment facilitation and service the real economy, the State Administration of Foreign Exchange ("SAFE") issued the Provisions on the Administration of Centralized Operation of Foreign Exchange Funds by Multinational Corporations on August 5, 2015 (Huizhou [366] "No. 36"). Circular No. 36 (Circular No. 24, No. 23, Circular 23) on the issuance of the Provisions on the Administration of Centralized Operation of Foreign Exchange Funds for Multinational Corporations (Trial Implementation), which is the core change to allow transnational Company members to borrow the amount of foreign debt to implement the scale of net assets linked to the proportion of foreign debt self-discipline, breaking the previous 23 text with the difference between the provisions of the provisions of the amount of foreign debts. We understand that multinational corporations' foreign exchange pool can be a very useful tool for multinational companies to make full use of both domestic and foreign financing markets to mediate capital costs. According to the State Administration of Foreign Exchange data show that as of the end of 2015, more than 50 multinational companies to carry out the proportion of foreign debt management, the actual borrowing of nearly 10 billion US dollars.

First, the advantages of multinational foreign exchange fund pool borrowing foreign debt

Compared with the ordinary foreign-invested enterprises and non-applicable regional cross-border RMB loans special policy of Chinese-funded enterprises, multinational companies in the scale of borrowing foreign debt and the threshold has a greater advantage.

The foreign-invested enterprises can only use their own foreign debts to borrow foreign debts and do not apply the special policy of regional cross-border RMB loans. There is no difference in the amount of foreign debts and the borrowing of foreign debts. The amount of each member company of a multinational company can be shared, and any member enterprise can borrow foreign debts within the total amount of foreign exchange funds pool of multinational corporations. Members can make use of the total amount of foreign exchange funds pool of multinational corporations to make up for their own lack of foreign debts or insufficient external debt Defects.

Two, 36, the main content of the adjustment

Circular No. 1.36 expands the scale of borrowable foreign debt for multinational companies

In the text of 23, the principle of betting difference is used to calculate the amount of foreign debt of multinational corporations. Therefore, only foreign member companies of multinational corporations can contribute foreign debt to foreign exchange funds pool of transnational corporations within the range of investment difference. In the 36th text, allow Chinese-funded enterprises to use their own net assets to participate in the calculation of the amount of concentrated foreign debts, while allowing foreign investment enterprises have their own choice of investment or net assets to participate in the calculation of the amount of concentrated foreign debt, once selected, the principle May not be changed. Therefore, multinational companies can borrow the scale of foreign debt to further expand. See below for specific case studies:

Assumptions: multinational companies A foreign exchange funds within the pool of foreign member companies B and Chinese enterprises C. Foreign member enterprise B's betting difference of $ 3 million and net assets of $ 2 million; Chinese-owned enterprise C's net assets equivalent to $ 2 million.