Regarding the use of offshore accounts

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We recently opened a Hong Kong offshore account, but we're not sure how to use it safely and in compliance with regulations. Will the customs and foreign exchange authorities check if we use the offshore account to receive payments? What should we do if the customs declaration form and the receiving account don't match? If a client questions whether the account belongs to a mainland company, how can we explain this without losing the deal?

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Lucas Liu
Lucas LiuYears of service:8Customer Rating:5.0

Senior Operations ConsultantStart a Chat

The most critical compliance requirement for using offshore accounts is the "Three Flows Consistent" principle: the flow of goods,funds,and documents must form a logical closed loop. The State Administration of Foreign Exchange (SAFE) and customs authorities will verify the "domestic consignor/consignee" information on the customs declaration form against the actual receiving account through the e-port system. If your company acts as an exporter but receives payments from offshore accounts,you must clearly specify the overseas receiving account information in the "Foreign Trade Operator Registration Form" filed with customs. Failure to do so may trigger B-class enterprise supervision。

Special note: the amount received in the offshore account must match the customs declaration amount. For partial payments,each transaction must be traceable to a specific customs declaration number. Additionally,SAFE intensively investigates "offshore speculative trading" in 2024. If goods do not actually enter or exit the country but are merely booked through offshore accounts,you must provide complete proof of ownership transfer and a reasonable business purpose explanation. Otherwise,you may face risks of currency evasion or false declaration。

It is recommended to retain complete trade contracts,invoices,bills of lading,and bank statements for each transaction,and ensure that the product names,quantities,and amounts on these four documents are fully consistent.

Linda Gao
Linda GaoYears of service:7Customer Rating:5.0

Documentation SupervisorStart a Chat

From a logistics operation perspective, receiving payments through offshore accounts will directly affect your delivery schedule and the matching of customs clearance documents. It is recommended to prioritize EXW or FOB terms, so that the Shipper on the freight forwarder's bill of lading can be your mainland company, while receiving payments through offshore accounts, which is more acceptable to customers. If using CIF, when prepaying the freight, the shipping company will require the payment account to match the bill of lading consignor. In this case, you need to use offshore accounts to pay the ocean freight, otherwise there may be delivery issues at the destination port.

Practical tips:

- On the invoice, note "Payment via Hong Kong Office Account for Treasury Efficiency".

- On the shipping instructions and customs declaration forms, uniformly display the format of "Domestic consignor + overseas settlement account".

- After receiving payments through offshore accounts, if you need to pay domestic factory invoices in RMB, it is essential to use compliant cross-border RMB settlement systems to avoid exchanging money through underground banks. Otherwise, the VAT invoices for export tax rebates may be questioned by the tax authorities.

- For document flow, it is recommended to prepare internal settlement invoices that clearly show the entrustment relationship between the mainland company and the offshore company, which is convenient for subsequent audits.

Andy Guo
Andy GuoYears of service:3Customer Rating:5.0

Supply Chain Management ExpertStart a Chat

When clients question account information, never evade the issue. This is precisely an opportunity to demonstrate your company's international operating capabilities. Standard response: "To optimize global fund settlement efficiency, we have established a financial settlement center in Hong Kong. The account name belongs to our group's Hong Kong company, which is part of the same group as our mainland export entity. You can review our group structure certificate."

Prepare three documents in advance:

1. The mainland company's business license;

2. The Hong Kong company's registration certificate;

3. Group relationship proof or authorized collection letter.

Proactively providing these documents during the PI stage demonstrates professionalism far more effectively than responding after clients raise questions.

Negotiation strategy: If clients insist on using letters of credit but the issuing bank has concerns about offshore accounts, suggest a "back-to-back letter of credit" structure, with your mainland company acting as an intermediary. This meets clients' regulatory requirements without exposing your supply chain information. Remember: The more transparent and upfront you are, the more professional clients perceive you to be; the more secretive you are, the more distrust you invite.

For long-term clients, proactively offer: "If your financial audit requires it, we can provide additional account ownership proof documents." This statement instantly dispels 90% of concerns.

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