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 Enterpriseit 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 Venturea 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.
2BOT
Abbreviation for BuildoperateTransfer. 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.
3M&AMerge & Acquisition
Acquiring domestic companies by foreign investors
Including asset deal and share deal
4QFIIQualified 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〃)
2Requirements 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.
3Ways 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.
4Requirements 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
5Limitations 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
6Limitations 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
7Allowed 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.
8Documents 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
9Time 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 agreement30-60 days
冹 Resolutions of Board of Directors and announcement15 days
冹 Sending notices, holding of shareholders meeting, resolution an announcement45 days
冹 Signing on the agreement15 days
冹 Submitting for approval (Ministry of Commerce)15 days
冹 Principle reply30 days
冹 Opening an foreign exchange account and remittance of capital15 days
冹 Submitting the acquisition report and relevant documents to CSRC: 5 days
冹 Term for filing a demurral with CSRC15 days
冹 Confirmation and transfer of ownership10 days
冹 Issuance of approval certificate15 days
冹 Registration at the Administration of Industry and Commerce10 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.
1Limitations 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.
2Financial 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.
3Measures 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.
4Special 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
相关法律服务
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
外国投资者战略投资上市公司需满足哪些资格条件?
法律概念与规则解释:外国投资者对上市公司战略投资,是指外国投资者通过中长期战略并购方式取得上市公司A股股份的行为。根据相关监管规则,适格投资者须为依法设立并运营的外国法人或其他组织,财务稳健、资信良好且具备成熟管理经验;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;若以其境外母公司名义申请,则母公司实有资产总额不低于1亿美元或管理的资产不低于5亿美元;同时须具有健全的治理结构和内部控制制度,且投资者及其母公司最近三年内未受到境内外监管机构的重大处罚。案件事实与实务场景引用:文章指出,若投资者为外国公司的全资海外子公司,除提交常规文件外,还须提交母公司出具的不可撤销承诺函,承诺对投资者的投资行为承担连带责任。这一安排常见于跨国集团通过特殊目的公司实施战略投资的情形,监管机构借此将责任追溯至集团层面,防止壳公司规避资格要求。实务指引与风险提示:投资者应提前准备经公证认证的财务资料、资信证明及无处罚记录声明,并审慎评估母公司连带责任承诺的商业风险。若通过子公司投资,需确保承诺函内容明确、不可撤销,并覆盖投资全周期。对于财务指标的计算口径,应以合并报表为基础,避免因口径差异导致资格不符。此外,治理结构与内控制度的证明材料应体现实质合规,而非形式文件。
战略投资上市公司有哪两种方式及审批流程?
法律概念与规则解释:外国投资者战略投资上市公司,在交易结构上属于股份取得行为,现行规则允许两种路径:一是上市公司向投资者定向发行新股,二是投资者通过协议受让现有股东持有的股份。两种方式均须履行商务部门与证券监管部门的审批或备案程序,并最终完成外商投资企业批准证书的取得及工商变更登记。案件事实与实务场景引用:文章详细列明了定向发行的五步流程:董事会和股东大会通过决议、上市公司与投资者签署定向发行合同、上市公司向商务部报送申请并取得原则性批复、上市公司向中国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。协议转让流程则为:董事会和股东大会决议、签署转让合同、投资者向商务部报送申请、取得批准后到证券交易所办理股份转让确认并在证券登记结算机构办理过户登记、向证监会备案,最后取得批准证书并办理工商变更。实务指引与风险提示:定向发行路径中,商务部原则性批复与证监会核准存在前后衔接关系,实务中应预留充足时间并确保申请材料的一致性。协议转让路径中,投资者须在取得商务部批准后方可办理交易所确认和过户,顺序颠倒可能导致交易无效。无论哪种方式,合同条款应明确生效条件与审批风险分配,避免因审批延迟产生违约争议。此外,完成交易后须及时办理外商投资企业批准证书和工商变更,否则可能影响后续股份处置及分红等股东权利。
战略投资持股比例与锁定期有哪些限制?
法律概念与规则解释:外国投资者对上市公司战略投资,在持股比例和股份转让方面受到特定规则约束。持股比例规则旨在确保投资具有中长期战略属性,防止短期套利;锁定期规则则通过限制转让期限维持上市公司股权结构的稳定。相关规则要求首次投资完成后持股比例不低于百分之十,并区分实际控制、要约收购触发点及行业特别限制等情形。案件事实与实务场景引用:文章明确,战略投资可以分期进行,但首次投资完成后取得的股份比例不得低于上市公司已发行股份的百分之十;若收购后投资者对上市公司形成实际控制,须向证监会提交收购报告书及相关文件;当收购股份达到百分之三十或以上时,投资者须向上市公司所有股东发出收购要约。在转让限制方面,投资者取得的上市公司股份三年内不得转让,且不得在承诺的持股期限内转让。此外,对于法律法规明确规定了外资持股比例的行业,投资者须遵守该比例限制;对于禁止外资进入的领域,投资者不得对相关上市公司进行投资。实务指引与风险提示:投资者应审慎设计分期投资节奏,确保首期持股达到百分之十门槛,避免因比例不足导致交易被否。若投资方案可能触发百分之三十要约收购义务,应提前评估全面要约的资金成本与市场影响,或依法申请豁免。三年锁定期意味着投资者须做好长期资金安排,不得通过代持、收益权转让等安排变相规避。对于行业限制,应逐一核查上市公司所属行业的外资准入政策,避免投资于禁止类领域。违反持股比例或锁定期规则可能导致行政处罚、交易无效或股份转让受限等后果。
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



