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2026-08-20From "Formal Compliance" to "Substantive Compliance" – A Shift in Regulatory FocusAgainst a backdrop of geopolitical volatility and fiscal pressure, "substance over form" and "reasonable commercial purpose" have become core principles across tax, accounting and legal regulation. This article traces their historical
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2026-08-20Outbound Investment Series | State Council Decree No. 837 Takes Effect – A Compliance Guide for Technology Transfer in Overseas InvestmentsOn 1 July 2026, the State Council Decree No. 837 (hereinafter "Decree No. 837" or the "Regulations") on outbound investment officially took effect. Article 13 draws a clear red line: investors shall not export or use goods, technologie
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2026-08-20Outbound Investment Series | 1 August Take Effect! Thailand DBD Order No. 2/2569 Brings New Substantive Control Rules – Nominee Shareholding Loopholes for Chinese Investors Are ClosingOn 1 August 2026, Thailand's Department of Business Development (DBD) issued Order No. 2/2569, marking a fundamental shift in foreign investment regulation—from documentary compliance to substantive control and economic substance review. Previously, DBD
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2026-07-02New Policy Focus | An Analysis of the Action Plan for Consolidating, Stabilizing and Optimizing Foreign Investment UtilizationRecently, the Ministry of Commerce (MOFCOM), together with the National Development and Reform Commission (NDRC) and the Ministry of Finance, jointly issued the Action Plan for Consolidating, Stabilizing and Optimizing Foreign Investment Utilization(herei
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2026-06-11Breaking! Effective July 1 – In-depth Interpretation of the State Council's New Overseas Investment Regulations | Series III: After the New Regulations, Which Key Issues Remain Unresolved?The Regulations of the State Council on Outbound Investment(State Council Order No. 837, hereinafter "Order No. 837"), officially announced on June 1, 2026, represents a landmark piece of top-level legislation in the history of China's outbound
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2023-07-14OFFSHORE Series | Changes in the Typical Structure and Registration Requirements for the Cayman Islands Exempted Limited Partnerships (ELPs)
Following the publication of our article "Understanding the Registration and Operation of Hong Kong Limited Partnership Funds (LPFs)" on the "China Wealth & Wisdom" WeChat official account, we have received inquiries from clients r
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2023-07-04OFFSHORE Series | A Comprehensive Guide to the Registration and Operation of Hong Kong Limited Partnership Funds (LPFs)
Recently, the news of Zhang Yiming, former CEO and controlling shareholder of ByteDance, establishing a limited partnership fund (LPF) in Hong Kong has attracted considerable attention. According to reports, the limited partnership fund is a privately hel
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2023-06-26OFFSHORE Series | Starting from June 12th, there are new changes for Hong Kong companies applying for residency to avoid double taxation!
For cross-border investors holding Hong Kong companies, applying for Hong Kong residency is crucial as it is key to enjoying the benefits of Double Taxation Treaties/Arrangements. On June 8th, 2023, the Inland Revenue Department of the Hong Kong Special
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2023-06-14OFFSHORE Series | Why is the "magical" number 25% frequently seen when establishing a Hong Kong company?
As a determining factor, the number 25% is crucial in the establishment and operation of offshore entities. For instance, when setting up a Hong Kong company, we frequently encounter the number 25% in the context of equity structure and proportions.
