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Corporate Service - China

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FAQ Concerning ODI Annual Report Filing for Year 2019

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Annual report of outbound direct investment (hereinafter referred to as “ODI”) for year 2019 has begun. It is the liability and obligation of enterprises with ODI activities to submit the annual report. Due to the impact of COVID-19, adjustments have been made for year 2019’s report. What are the specific requirements? This article aims to solve commonly asked questions in the form of Q&A for clients’ reference.

Q:
Which companies need to submit annual report?
A:
The following 2 types:

1.
Overseas invested enterprises that have completed the record filing or approval before December 31, 2019 (note: the issuance date of the Enterprise Outbound Investment Certificate shall prevail)
2. The office, branch, project departments and management departments etc. established for more than 1 year (including 1 year) by enterprises registered in Beijing for the implementation of foreign contracted projects should also be submit the report in according to the facts.

Q:
When is the deadline for the annual report?
A:
June 30, 2020.

Q:
What are the consequences if annual report cannot be filed within stipulated period?
A:
Enterprise that fail to submit annual report on time will be included in the blacklist of Ministry of Commerce and publicized on the internet, accept statistics punishment, and cannot apply for special fund.

Q:
When two or more domestic investors jointly invest abroad, do they all need to submit annual reports?
A:
If the domestic investors are two or more investment entities and holds the same proportion of shares, the company that made the original record filing shall submit the report.

Q:
The audit reports of some overseas invested enterprises for year 2019 have not been issued yet. How should they fill in the audited financial data?
A:
Please refer to the audited financial data of the previous year.

Q:
What do the data include?
A:
The required data include FDIN1, FDIN2 and FDIN3.

Other data may be required based on the actual situation of the enterprise. It is advisable to engage professional agencies like Kaizen to prepare and file the report to avoid inaccurate and false filing.

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