Speech: New Investment Vehicles in China (2007)

文章摘要 本演讲系统梳理了2007年前后外国投资者进入中国市场的传统与新型投资工具。传统工具包括外商直接投资中的合资、合作与独资企业,以及BOT、并购和QFII。新型工具聚焦外国投资者对上市公司战略投资与收购上市公司,涉及投资者资质、定向发行新股与协议转让程序、首次投资后持股不低于百分之十、实际控制须提交收购报告、持股达百分之三十或以上须发出要约、行业准入限制以及股份三年限售等核心合规要求。该内容为理解外资通过资本市场进入中国的监管框架提供了实务参考。

This speech was made at "2007 New Environment For Foreign Investment In China".

Contents

Part One   Traditional Investment Vehicles
Part Two   New Investment Vehicles (I) Strategic Investment in Listed Companies
Part Three  New Investment Vehicles (II) Acquisition of Listed Companies

 

Part One  Traditional Investment Vehicles

Main Traditional Investment Vehicles

1. Foreign Direct Investment (FDI): EJV, CJV, WFOE

2. BOT

3. M&A

4. QFII

1. Foreign Direct Investment (FDI): mainly includes Equity Joint Venture (EJV), Contractual Joint Venture (CJV) and Wholly Foreign Owned Enterprise (WFOE)

(1) Sino-foreign Equity Joint Venture Enterpriseit is an enterprise jointly invested by foreign companies, enterprises, other economic organizations or individuals and Chinese companies, enterprise or other economic organizations

The characteristic of the Joint Venture is joint investment, joint operation, and sharing the risk, profit and loss according to the respective ratio of contribution.

The contribution of each party will be converted to relevant ratio, and the ratio of foreign investors shall not be less than 25%.

Joint Venture is the earliest and most popular way to invest in China. It still has some importance at present.

(2) Sino-Foreign Contractual Joint Venturea joint venture established by foreign companies, enterprises and other economic organizations or individuals and Chinese companies, enterprises or other economic organizations. It is jointly invested by parties or the parties provide conditions for operation. The rights and obligations of each party shall be agreed in the contract.

Usually, the foreign parties will provide all or most of the capital and the Chinese parties will provide lands, premises, equipment and utilities, and sometimes, capital in a certain amount.

(3) Wholly Foreign Owned Enterprise: an enterprise established in China according to the laws of China, whose total investment is made by foreign companies, enterprise, other economic organizations or individuals.

 

2BOT

Abbreviation for BuildoperateTransfer. The government will grant an enterprise a concession for a term, to permit it to finance, build and operate a special infrastructure, and permits it to pay back the loans, recover the investments and make profits by charging the users or selling products. When the concession expires, the infrastructure shall be transferred to the government for free.

 

3M&AMerge & Acquisition

Acquiring domestic companies by foreign investors
Including asset deal and share deal

 

4QFIIQualified Foreign Institutional Investors

Which refers to the foreign fund management institutions, insurance companies, securities companies and other assets management institutions that invest in Chinaˇs securities market in accordance with the relevant provisions after being approved by China Securities Regulatory Commission and granted an investment quota by State Administration of Foreign Exchange.

 

Part Two  New Investment Vehicles

New Investment Vehicles include:
Strategic investment in listing companies Acquisition of listing companies

1 Strategic Investment

Foreign investors may obtain the A share stock of the listed companies that have completed the share-trading reform and the newly listed companies after the share-trading reform through a scale of medium and long-term strategic merger Investment.
¨Measures for the Administration of Strategic Investment in Listed Companies by Foreign Investors〃 (December 31, 2005, hereinafter referred to as ¨Measures〃)

2Requirements on Investors:

(1) It is a foreign legal person or other organization that is established and operated according to law, with sound finance, good credit standing, and mature management experiences;

(2) Its total overseas paid-in capital shall be no less than USD 100 million or the total overseas paid-in capital under its management shall be no less than USD 500 million; or the total overseas paid-in capital of its overseas parent company is no less than USD 100 million or the total overseas paid-in capital under the management of its parent company shall be no less than USD 500 million;

(3) It has sound governance structure and sound internal control system, and criterions for management acts; and

(4) It (including its parent company) has no records of grave penalties by any regulatory institution both home and abroad within the past three years.

When the investors are subsidiaries of the foreign company

Any foreign company (parent company) meeting the Above requirements may make strategic investment through its wholly owned overseas subsidiaries (investors), the investors shall, apart from submitting the required documents, submit the letter of irrevocable commitment of the parent company on assuming joint and several liabilities for the investment acts of the investors to the Ministry of Commerce.

3Ways of Strategic Investment

Strategic investment in listed companies is a kind of share acquisition

Two Ways
Directional issuance of new shares
Transfer by agreement

A. Procedures for directional issuance

(1) Board of Directors and Shareholders meeting adopt resolutions;
(2) The listed company signs a directional issuance contract with the investor;
(3) The listed company submits the relevant application documents to the Ministry of Commerce and obtains the letter of principle reply of the Ministry of Commerce
(4) the listed company shall submit the application documents for directional issuance to China Securities Regulatory Commission (hereinafter referred to as the CSRC), and the CSRC shall grant approval according to law; and
(5) After completing the directional issuance, the listed company shall obtain the certificate of approval for foreign-funded enterprises at the Ministry of Commerce, and go through alteration registration at the administrative department of industry and commerce upon the certificate of approval.

B. Procedures for transfer by agreement

(1) Board of Directors and Shareholders meeting adopt resolutions;
(2) The listed company signs a directional issuance contract with the investor;
(3) The investor submits the relevant application documents to the Ministry of Commerce;
(4) go through the formalities for confirmation of share transfer at the securities exchange after it has obtained the aforesaid approval, and apply for going through registration and transfer formalities at the securities depository and clearing institution, and report to the CSRC for archival filing;
(5) After completing the transfer under an agreement, the listed company shall obtain the certificate of approval for foreign-funded enterprises at the Ministry of Commerce, and go through alteration registration at the administrative department of industry and commerce upon the certificate of approval.

4Requirements on Relevant Proportions of Shares

冹 The investment may be made by stages, but the proportion of shares obtained by it after completing initial investment shall be no lower than 10% of the shares having been issued by the company

冹 If after acquisition, the investors have actual control on the listed company, it shall submit the acquisition report and relevant documents to CSRC

冹 When the acquired share meets 30% or more, the investors shall place offers to all of the shareholders of the listed company to purchase their shares

5Limitations on Industries

For the industry for which there are clear provisions by any law or regulation on the proportion of shares held by a foreign investor, the proportion of shares of the aforesaid industries held by an investor shall comply with the relevant provisions; for any fields to which foreign investment is prohibited by any law or regulation, the investor shall not make investment in any listed company in the aforesaid field

6Limitations on transfer of the acquired shares of the listed companies

Shall not be transferred within three years
Shall not be transferred within the promised shareholding period

7Allowed sale and purchase of securities by foreign investors
(1) The A share stock of a listed company held by the investor for making strategic investment may be sold after the expiry of shareholding period in its promise;

(2) In case the investor purchases by offer in accordance with the relevant provisions of the Securities Law, it may purchase the shares sold by A share shareholders of the listed company within the period of the offer;

(3) The non-tradable shares held by the investor before the share-trading reform of a listed company may be sold after the share-trading reform is completed and the expiration of the time limit for sale prohibition;

¨Measures for Administration on Share-trading Reform of Listed Companies〃 provides that the sales of the original non-tradable shares of the listed companies after reform shall be in accordance of the following provisions:
(1) The aforesaid shares may not be listed for trading or be transferred within twelve months as of the day when the reform scheme is implemented; and

(2) The holders of original non-tradable shares holding 5% or more of the shares of a listed company that sell their original non-tradable shares through listing in a stock exchange after the time limit as prescribed in the preceding item expires may not sell 5% or more of the total shares of the company within twelve months and may not sell 10% or more of the total shares of the company within twenty-four months.

4. The shares held by the investor before the public issuance of a listed company for the first time may be sold after the expiry of the time limit for sale prohibition; and

5. Before the expiry of the share holding period as promised by an investor, if there is necessity to transfer its shares due to its bankruptcy, liquidation, or mortgage, or other special reasons, it may transfer its shares upon the approval of the Ministry of Commerce.

8Documents to be submitted

The listed companies or investors shall submit the following
documents to the Ministry of Commerce

1. Application Letter for Strategic Investment

2. Strategic Investment Scheme;

3. Directional issuance contract or share transfer agreement;
4. Opinions of a recommendation institution (in case of a directional issuance) or legal opinions;
5. The letter of commitment for holding shares incessantly by the investor;
6. Statements of the investor on its having no records of grave punishment by any regulatory institution both home and abroad within three years, and statements on whether it has any other record of non-grave penalties;
7. The registration certificate of the investor that has been notarized and certified according to law, and the identity certificate of the legal representative (or the authorized representative);
8. The statements of assets and liabilities of the investor in recent three years, which have been audited by a certified accountant

9Time limits on Completion of Strategic Investment

An investor shall start up its strategic investment act within 15 days from the date of settling the foreign exchange for the capital, and shall complete the strategic investment within 180 days from the day of principle reply.

Specific time schedule

冹 Due diligence, auditing and valuation: 30-60 days
冹 Negotiation and draft of share transfer agreement30-60 days
冹 Resolutions of Board of Directors and announcement15 days
冹 Sending notices, holding of shareholders meeting,  resolution an announcement45 days
冹 Signing on the agreement15 days
冹 Submitting for approval (Ministry of Commerce)15 days
冹 Principle reply30 days
冹 Opening an foreign exchange account and remittance of capital15 days
冹 Submitting the acquisition report and relevant documents to CSRC: 5 days
冹 Term for filing a demurral with CSRC15 days
冹 Confirmation and transfer of ownership10 days
冹 Issuance of approval certificate15 days
冹 Registration at the Administration of Industry and Commerce10 days

 

Part Three  New Investment Vehicles (II)
 Acquisition of Listed Companies

1 Limitations on investors
2 Financial Accountants
3 Measures of Acquisition
4 Special rules on acquisition of listed companies by foreign investors

The ¨Measures for the Administration of the Takeover of Listed Companies 〃 (hereinafter referred to as ¨Measures〃) promulgated by the CSRC on July 31, 2006 has a comprehensive provisions on the acquisition of listed companies, which applies to the acquisition of the companies listed on the domestic securities exchanges. The Measure shall also apply to the companies which are listed both in the mainland China and Hong Kong.

1Limitations on Investors

If it is under any of the following circumstances, a Listed company shall not be taken over:
(1) The purchaser owes a large amount of debts, and has not paid its due debts, and the said circumstance is in a continuous state;

(2) The purchaser has ever committed any major illegal act or has ever been suspected of being involved in any major illegal act within the recent three years;

(3) The purchaser has ever committed any serious credit-breaking act in the securities market within the recent three years;

(4) The purchaser, if being it is a natural person, is under any of the circumstances as prescribed in Article 147 of the Company Law; or

(5) Any other circumstance as prescribed by the laws or administrative regulations or as recognized by the CSRC under which no listed company can be taken over.

2Financial Accountants

The Measures requires the purchasers to engage financial accountants, who shall be liable for investigation of the capacity of the purchasers, purpose of acquisition, actual strength, creditability records, sources of capital and the abilities to perform contracts. It shall pay attention to whether there is misconducts during the acquisition. It shall give guidance on standardizing the operation of securities market, and continue to give guidance to purchasers within 12 months after the acquisition is completed, to prevent infringing the lawful rights and interests of the listed companies and medium and minority shareholders by the investors.

3Measures of Acquisition

The Measures allows the purchasers to adopt various measures to acquire the listed companies according to the number of shares, such as through securities exchange (namely secondary market), tender offer, acquisition by agreement, directional issuance, indirect acquisition, administrative distribution or transfer. These measures can be adopted independently, or in combination.

4Special rules on acquisition of listed companies by foreign investors

冹 In compliance with the requirements on state industrial policies and industrial access
冹 Approval by Ministry of Commerce
冹 Application of laws of China, and governed by the Chinese courts or arbitral institutions

杨春宝一级律师简介

杨春宝一级律师,大成上海高级合伙人、资本市场部主任、国资基金研究中心主任,大成中国区私募基金专业带头人、科技与文化法律研究中心联合牵头人。执业30余年,长期从事私募基金、投融资、并购重组法律服务,尤其对对赌研究颇深且具有非常丰富的实战经验,并专注于金融机构股权投资业务。2004年起多次入选The Legal 500"私募基金"和"公司与商业"等境内外各类律师榜单,代理的中国法院首例适用外国法律审理外国公司的董事损害小股东权益纠纷案入选上海高院发布的《上海法院域外法查明典型案例》和威科先行"要案头条"。入选上海涉外法律人才库、上海市司法局鼎新法治人才库、上海国有企业改制法律顾问团,具有上市公司独立董事任职资格,系多家知名高校的兼职教授或兼职研究生导师及上海市商务委跨国经营人才培训班讲师。出版《私募股权投资基金风险防控操作实务》等16本投融资法律专著。了解更多

常见法律问题

战略投资上市公司需满足哪些条件?

外国投资者对上市公司战略投资,是指符合条件的外国投资者通过中长期战略并购方式,取得已完成股权分置改革上市公司或股改后新上市公司的A股股份。规则核心在于投资者须为依法设立、财务稳健、信用良好、具有成熟管理经验的外国法人或其他组织,并具备健全治理结构与内部控制制度。根据演讲内容,投资者境外实有资产总额不低于1亿美元,或管理的境外实有资产总额不低于5亿美元;若投资者为境外母公司全资子公司,母公司满足上述资产要求,且母公司须出具不可撤销承诺函,对子公司投资行为承担连带责任。投资者及其母公司近三年不得有境内外监管机构重大处罚记录。实务中,应提前准备审计报告、资信证明、治理文件及母公司承诺函,注意资产口径为境外实有资产或管理资产,并以合并或母公司层面论证。若资质不达标,定向发行或协议转让均难以通过商务部门原则批复;外资比例、行业准入也可能构成障碍。应在交易前期进行合规预判,避免因主体资格欠缺导致交易终止。

战略投资上市公司有哪些方式与程序?

战略投资上市公司本质是股份收购,主要有两种方式:定向发行新股和协议转让。定向发行程序中,上市公司董事会与股东大会通过决议,与投资者签订定向发行合同,向商务部报送申请并取得原则批复,再向证监会提交定向发行申请并获得核准,完成发行后取得外商投资企业批准证书并办理工商变更登记。演讲指出,协议转让程序相似,但由投资者向商务部提交申请,取得批准后到证券交易所办理股份转让确认,在证券登记结算机构办理登记过户,并向证监会备案,完成后同样取得外商投资企业批准证书并办理工商变更登记。两种路径在报批主体、前置审批和登记环节存在差异,实务中需根据交易结构选择。风险提示方面,定向发行涉及上市公司再融资审核,周期较长且受市场与监管政策影响;协议转让需关注出让方股份是否受限、是否存在质押或冻结,并确保交易所确认与登记结算衔接。若涉及国有股东或特殊行业,还需履行国资、行业监管等额外程序。未取得商务部门原则批复前,不宜对外披露确定性交易安排,以免构成误导性陈述或违约。

战略投资上市公司持股与限售有何限制?

外国投资者战略投资上市公司,首次投资完成后取得股份比例不得低于该公司已发行股份的百分之十,投资可以分期进行,但首期完成后即须满足该下限。若收购后对上市公司形成实际控制,须向证监会提交收购报告及文件;若取得股份达到百分之三十或以上,则须向全体股东发出收购要约。行业方面,法律对特定行业外资持股比例有规定的,须遵守;禁止外资进入的领域,不得投资该领域上市公司。演讲明确,投资者取得的上市公司股份三年内不得转让,且不得在承诺持股期限内转让。若通过定向发行取得,限售期起算与发行完成、登记日相关;若通过协议转让取得,则从过户登记完成起算。实务中,若投资者为母公司全资子公司,母公司连带责任承诺也会影响后续退出安排。风险提示:三年限售与要约义务会显著影响资金退出节奏,交易文件中设计分期投资、对赌或回购条款时,须注意不得违反限售与要约规则。若持股达到百分之三十触发要约,需提前准备要约资金与信息披露。行业限制方面,应核查产业政策与外资准入规定,避免投资禁止类领域。实际控制认定不只看持股比例,还可能结合董事会席位、表决权安排等因素综合判断。

以上内容仅供参考,不构成法律意见。如需专业法律服务,请联系杨春宝一级律师:chambers.yang@dentons.cn

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