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
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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