Non-Trade Outbound Payment Compliance Services
1. Why Non-Trade Outbound Payments Are Challenging for FIEs in China
For non-trade outbound payments (e.g., service fees, tech fees, management fees, consulting fees, dividends, related-party transactions), the challenges are not simply “fill out a form and go to the bank.” In real practice, foreign-invested enterprises often face:
• Payment rejections due to incomplete documentation
• SAFE (State Administration of Foreign Exchange) queries about justification
• Tax authorities demanding explanations on payment nature
• Mismatches between FX payment logic and tax position
• Contract, invoice, and expense misalignment
• Inability to defend the payment during audits/inspections
The issue isn’t procedural — it’s whether your compliance logic is defensible and explainable.
We deliver compliance-oriented advisory services for non-trade outbound payments, not mere “procedure handling.” The service focuses on helping foreign-invested enterprises:
• ✔ Validate the legitimacy and tax impact of payments
• ✔ Design defensible justification logic for banks, SAFE, and tax authorities
• ✔ Establish internal controls and approval processes
• ✔ Reduce risk of audits, inspections, and regulatory queries
3. What Support We Can Provide
① Payment Compliance Risk Assessment
We help your company:
• Analyze payment nature and transaction background
• Determine whether it qualifies as non-trade payment
• Identify potential tax and FX reporting risks
• Deliver compliance recommendations and risk ratings
Deliverable Example: Compliance Assessment Report
② Documentation & Justification Logic
We assist in preparing:
• Contracts, invoices, and payment rationale documents
• Defensible explanation logic (bilingual)
• Bank and SAFE submission support materials
• Risk anticipation and alternate reasoning
Deliverable Example: Bilingual Explanation Logic Pack
③ Internal Control & Process Design
We help your organization establish:
• Payment approval workflows
• Expense classification and accounting guidelines
• Compliance documentation management
• Audit-ready explanation mechanisms
Deliverable Example: Compliance Control Handbook
④ Regulatory Support & Exception Handling
In case of:
• Bank rejections
• SAFE queries
• Tax inquiries
• Audit inspections
We provide:
• Exception handling strategies
• Drafting of response letters and supporting documents
• Communication recommendations with regulators
Deliverable Example: Exception Response Pack
• ✔ Compliance Risk Assessment Report
• ✔ Bilingual Explanation Logic Pack
• ✔ Compliance Control Process Manual
• ✔ Submission Package for Bank & SAFE
• ✔ Exception Handling Strategy & Templates
• Foreign-invested enterprises making non-trade outbound payments in China
• Companies with tax or FX compliance questions
• Enterprises frequently facing bank rejections or SAFE inquiries
• Organizations seeking standardized internal controls and defensible logic
6. Relationship With Your Other Compliance Products
This service complements your existing offerings:
• Entity Setup → Establish legal presence
• Accounting & Tax Compliance → Build foundational compliance
• Non-Trade Payment Compliance → Address outbound payment risk
• Export VAT Advisory → Improve VAT refund consistency
• Compliance & Risk Advisory → Monitor and report risk holistically
This service overview is based on practical experience and is for general compliance reference only. It does not constitute legal, tax, or foreign exchange advice for any specific situation.
We do not make decisions for you; we only help you clarify facts and risks.
Phone : 400 800 7472
Email : info@rtfcpa.com
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