Why Set up Multiple Layers of Offshore Companies: VIE Structure

Why do many companies incorporate multiple offshore companies with multiple layers? In fact, it is very common to have a two-tier or multi-tier offshore company structure, called VIE structure.
PART/1 Why VIE structure?
1 To avoid risks 
By using an offshore incorporated company as a parent company, and then using that parent company to hold companies for different purposes located in different jurisdictions around the world, you can use your limited liability to avoid the risk of being the controlling party or the ultimate beneficiary. Whether for investment, trade or services, offshore companies are the best choice for multinational business organizations due to the simplicity of the formation and dissolution process, speedy filing, confidentiality and zero tax.For proper planning of cross-border business transactions, companies incorporated in some low-tax countries and regions have become a powerful tool to be used in conjunction with an offshore company and to set up a compliant structure, e.g. BVI, Cayman, Marshall, Seychelles, etc.

2 For smooth transfer of ownership of assets
This is often the case for companies with offshore listings or investments, so-called ‘red chip structures’ or ‘offshore investment structures’. For companies listed in the United States, Hong Kong, etc., if the parent company registers a subsidiary in Seychelles, the injection and withdrawal of assets from the subsidiary is not subject to the laws of the parent company’s location.The operation of China Unicom is an example of this: its parent company is the BVI Unicom Group, which owns 51 per cent of the A-share China Unicom 600050. in 2000, Unicom 0762 was incorporated and listed in Hong Kong. In order to inject the assets of Unicom’s A-share into Unicom 0762 to help it raise funds in Hong Kong and increase its share price, Unicom Group registered another BVI company, Unicom New Century, as a wholly-owned subsidiary of BVI Unicom. Subsequently, Unicom Group injected the assets of the northern provinces of its CDMA network into BVI Unicom New Century, and Unicom 0762 then acquired BVI Unicom New Century to complete the transfer of the assets.

3 For reorganization of overseas assets
This situation is common in companies that have undertaken overseas expansion but failed to plan their shareholding structure properly.For example, a large state-owned import and export enterprise (unlisted) in the publishing industry had expanded over a dozen branches and offices in Japan, the United States, Europe and South America in the 1990s for the purpose of business expansion. In addition to some of the branches being wholly-owned, many of the organizations were joint ventures with local partners, and even cross-shareholding occurred. In recent years, this company needs to prepare for listing and faces reorganization of overseas assets and earnings. However, due to the different shareholdings, there were a lot of troubles in profit statistics, tax collection and asset accounting.

So the company used a multi-layer BVI structure: firstly, a BVI company (BVI1) was set up as a wholly-owned subsidiary of the domestic company. The subsidiary then registers a number of BVI a, BVI b… etc., each BVI corresponding to an overseas company. The subsidiary then registers a number of BVI a, BVI b…, etc., each corresponding to an overseas joint venture, and transfers ownership of the parent company to BVI a, b, c, d by way of equity transfer, with BVI 1 ultimately taking control of the company, and classifying all BVI a, b, c, d as wholly-owned subsidiaries of BVI 1.

In this way, the structure of overseas assets is sorted out through the form of multi-layer BVI, which is convenient for future equity operations and spin-offs. On the other hand, all overseas profits can be treated as investment income of the domestic company instead of operating profits, thus exempting or reducing the corporate income tax.

PART/2 VIE structure construction mode: 
BVI + Cayman + Hong Kong company
The first layer of VIE structure construction – the establishment of BVI company
BVI registered offshore company, simple procedures, low cost, no field operations do not need to pay taxes, has a high degree of confidentiality. Because of all the advantages of BVI company, it is convenient to set up the first layer of structure in BVI for the major shareholders for the listed company, and at the same time to let go of some of the restrictions of the lock-up period, because of the high confidentiality, but also to hide some of the problematic shareholders, for the company, no on-site operation and no tax, only need to pay a very small amount of management fees every year.
The second layer of VIE structure construction – the establishment of a Cayman company
For the use of Hong Kong, China, red chip listing of enterprises, usually in the BVI company will set up a Cayman company, the establishment of a company in Cayman procedures are relatively simple, for the BVI, its regulation is more stringent, but for other non-tax havens compared to the normal country, its policy is much more relaxed.Note: Although the conditions of BVI company is better, but for the company set up in BVI, its shareholders’ information is confidential, no need to do the audit report every year, it is unable to pass the listing supervision, in this kind of under, the general enterprise will choose the more strict supervision, but no tax Cayman company as the main body of overseas listing. In addition, the main body of the listing will be set up in the Cayman company, because at present, Hong Kong, China only allows the registered place in Hong Kong, China, Bermuda, Cayman, the four companies listed in Hong Kong.

The third layer of VIE structure construction – the establishment of Hong Kong, China company
Chinese companies indirectly listed through overseas, usually the last layer will be set up in Hong Kong, China company, mainly because of Hong Kong, China and the mainland have tax incentives. It is easier for a Hong Kong, China company to invest directly in the mainland for tax relief. Entities in China want to repatriate profits, if the offshore company is set up in a country other than Hong Kong, China, the general tax is 20%, but if set up in Hong Kong, China, as low as 5%.

PART/3 How to transfer profits under 
VIE structure
Under the VIE structure, profits are generally generated in the domestic operating entity, and the path of profit transfer is usually as follows: domestic operating entity → WFOE → Hong Kong, China company → offshore holding company. Since the WFOE is 100% controlled by the Hong Kong company, and the Hong Kong company is 100% controlled by the offshore holding company (i.e., the Cayman company in the figure above). Therefore, profits from the WFOE to the Hong Kong, China company, and further from the Hong Kong, China company to the offshore holding company, are in the form of dividend distributions from the “subsidiary to the parent company”.Under the VIE structure, since there is no equity control relationship between the domestic company and the WFOE, control is realized through the VIE agreement. Therefore, the profits generated by the domestic operating entity are also transferred to the WFOE through the VIE agreement, which is manifested in the following two aspects:

WFOE exclusively provides technical consulting services, business management and other servicesto the domestic operating entity and collects consulting service fees from the domestic operating entity;

Under the VIE structure, IP that can legally be held by the WFOE is often transferred to the WFOE, which then licenses it to the domestic operating entity and collects IP licensing royalties from the domestic operating entity.

The fees collected by the WFOE from the domestic operating entity in one or more of the above ways often account for all of the profits of the domestic operating entity, thus realizing the transfer of profits from the domestic operating entity to the WFOE.

In the VIE structure building process, BVI companies, Cayman companies, Hong Kong, China companies have their own division of labor and use, one is indispensable.

Red chip listing in Hong Kong, China, is most of the domestic Internet overseas listing enterprises respected way, its mode of operation is generally:

First in the British Virgin Islands (BVI), the Cayman Islands and other places to register offshore companies, and then use this offshore company agreement to control (VIE mode) domestic companies, the offshore company as a platform for the sale of preferred shares or convertible bonds to the fund or PE for private placement.

PART/4
Why is it popular to set up an offshore company in Cayman, BVI, Hong Kong?

(i) Perfect legal and judicial system, strong predictabilityCayman and BVI are the overseas territories of the United Kingdom, the legal system is the common law system of the United Kingdom, the political and legal system is very mature and stable, there will be no change of policy, and disputes can be appealed to the Privy Council of the United Kingdom, the legal outcome of the predictability of the public can win the trust of the public. As for Hong Kong, it has inherited the British common law system and has a complete legal system, and it is a special administrative region of China. Compared with the United States and Europe, entrepreneurs with Chinese backgrounds have a greater sense of intimacy with it, and its popularity does not need to be mentioned.

(ii) Cayman and BVI company law rules are flexible and easy to realize business purposes

In addition, Cayman and BVI company law rules are flexible, for example, share repurchase arrangements and even drag-along clauses, which are very important for investment and financing projects, are very difficult to be implemented under Chinese company law, but are much more flexible under Cayman and BVI company law.

PART/5
Why are Cayman companies usually the subject of overseas financing and 

listing for red-chip structures?

(i) Cayman companies have a higher degree of transparency and protection of shareholders’ rights than BVI companies.Most of the overseas financing and listing entities of China-backed red-chip structures are Cayman companies. BVI companies have stronger confidentiality than Cayman companies, which means that the transparency of information is poorer, and Cayman corporate governance (e.g., protection of shareholders’ rights) is better than that of BVI, so the relevant stock exchanges are more willing to accept Cayman companies as the listing entities. In addition, since BVI companies have stronger confidentiality, they are generally used as shareholders’ holding SPVs.

(ii) Historical differentiation of the Hong Kong Stock Exchange’s listing rules

In addition, prior to January 1, 2022, the Hong Kong Stock Exchange Listing Rules classified the domicile of the main body of the company to be listed into two categories:

Recognized Jurisdictions (Recognized Jurisdictions): Hong Kong, China, Cayman and Bermuda;

Acceptable Jurisdictions (Acceptable Jurisdictions): 21 jurisdictions including BVI. Compared to the Acceptable Jurisdictions including Cayman, company entities incorporated in the Acceptable Jurisdictions including BVI will need to additionally demonstrate in the Pre-A1 procedure that their rules do not provide less protection to shareholders than the Hong Kong law rules. Although the Hong Kong Stock Exchange Listing Rules, which will take effect on January 1, 2022, have deleted the above distinction between judicial regions, Cayman companies as listing entities in red chip structures are still the absolute mainstream, given that Cayman’s company law system and transparency are more complete than BVI, among other reasons.

Nowadays, VIE mode is an important channel for Chinese enterprises to go out, but it also increases the risk of enterprises involved in tax, therefore, the tax-related service agency chosen must be professional and able to escort enterprises in tax-related aspects. 

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