China

This discussion explored the complexities of cash pooling in China, a topic that frequently arises in treasury conversations. While the goal was to clarify the regulatory landscape and operational requirements, the findings reinforced the reality that rules remain open to interpretation and can vary significantly depending on the bank and regulatory body involved.

Peers examined the key distinctions between domestic and cross-border pooling, the regulatory approvals required, and the different approaches banks offer. The discussion also touched on challenges related to tax considerations, currency exposure, and the evolving stance of authorities on approvals and compliance.

Rather than a single, definitive framework, the session highlighted the diversity of experiences and strategies companies use to navigate cash pooling in China. For treasurers managing liquidity across borders, this report provides critical insights into practical considerations, regulatory nuances, and emerging trends. The full version offers further details on bank-specific practices, tax implications, and risk management approaches.

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Commentary

Geopolitical risk, or simply political risk, is a major challenge for treasurers. We had all become used to viewing Iran, North Korea and Myanmar as off limits, and handling issues in Venezuela and Argentina. But the Russian invasion of Ukraine and escalating trade tensions between the US, the EU and China have made the world a more dangerous place.

This call was scheduled at the request of one member, who was looking for ways to measure political risk, or at least get external indicators they can use to convince management to tread carefully. More on that below. But we quickly moved to discussing what to do, once you have identified the risk. After all, if management wants to do business in a risky country, treasury has to make it happen. 

Generally, peers participated in senior level discussions on strategy and objectives, but felt their main contribution was through managing the balance sheet:

• Cash repatriation: the main way treasurers can reduce immediate risk is by repatriating restricted and trapped cash. This often involves a cost: withholding tax in the case of dividends, or creating accounting losses on currency conversion. Tax departments and CFOs have to be persuaded this is the right thing to do. Several participants regularly circulate the amount of trapped cash by country to the business, and even the board of directors: this helps change attitudes.
• Change the business model: this is more difficult, but it can involve moving to invoicing in hard currency to reduce FX risk, or moving to selling through remarketers. One participant has moved from a single manufacturing location in China to multiple production sites in different regions. This was partly due to COVID disruptions and supply chain concerns, but it also addresses the potential exposure due to increasing tensions with China. 
• Change the funding structure: in some markets, participants have moved from funding via intercompany loans from offshore locations to onshore external borrowing. This reduces the net exposure – provided the company is willing to walk away from the local debt in a crisis. In turn, that raises a series of issues – but at least, it gives more options. It is often more expensive.
• Manage the accounting exposure: some

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Commentary

Do you remember the good old days, when the biggest issue many treasurers faced was implementing cross-border cash pooling with China? At CompleXCountries, we do – so we thought it was time to check up on the situation in China, as it starts to come out of the extended COVID restrictions, and the tensions between China and the US  continue.

Key takeaways:

• Business carries on in China. It is a major market for most large companies – several participants are doing acquisitions, or expanding their business operations. Business is growing: it is largely profitable, and generating cash.
• The regulatory environment remains complex, but easing continues. Cross border cash pooling works well, as does local pooling. In many places, it is now possible to settle tax and other statutory payments from accounts with foreign banks.
• Several participants are receiving cash via AliPay and WeChat, though none are yet using these tools to make payments. These settlements work well, but they create reconciliation problems, as the detail of the invoices being settled resides in a local system, which typically does not interface well to the international ERP systems.
• As is usual in China, there is some confusion over

Commentary

The way treasurers manage banking relations provides a key insight into how they approach their job. This session was no exception – and we had the additional benefit of input from senior banker in Asia and Advisory Board member John Laurens, who shared his view from the other side of the fence.

• Nearly everyone had the same goal: try to get the most efficient banking structure.
• This nearly always involves a general preference for dealing with core international relationship banks over having many local relationships
• However, one participant commented that local banks in Asia often have excellent technology and services – but it is difficult to get HQ to agree to go with them
• In any case, there are many situations where local banks are still required, to support tax payments or local payment systems. China, India, Korea and Japan were the countries where this was most frequent.
• In awarding business to banks, most companies tend to give a preference to the institutions who participate in credit facilities. Exceptions were made when justified by a specific service, but this could become an issue when credit needs increased.
• Several participants have either recently restructured their banking relationships, or are currently doing so. Comments:
  • It is very important to get the local team on board. They will usually accept the outcome and help if they own the decision, and can see clear benefits.
  • The RFP process is useful, but it is important to carefully check the responses. One participant found that banks often tried to sell capabilities they did not yet have – it is important to focus on what they can deliver today. They also found it was beneficial to use...please sign in to continue reading