Author: Acclime China


Key compliance requirements for companies in China

China has complicated administrative procedures and a set of corporate compliances different from that of many foreign nations. Companies must complete all compliance requirements to ensure the company is in line with national and local regulations and avoid penalties. This article provides you with a complete list of corporate compliance requirements for companies in China.

Ongoing business compliance requirements for companies in China

Annual Shareholders Meeting

The shareholders’ meeting must be held at least once every year. However, there is no statutory requirement when the meeting should be held.

The notice period for holding meetings is 15 to 20 days or as stated in the articles of association.

Matters to be decided in the shareholders’ meeting may include:

  • Amendments to the articles of association
  • Deciding the remuneration of directors and supervisors
  • Passing resolutions on company mergers, divisions, dissolution or liquidation
  • Passing resolutions on the increase or reduction of the registered capital
  • Reviewing and approving the reports of the board of directors
  • Reviewing and approving the reports of the supervisor or board of supervisors
  • Reviewing and approving the company’s annual financial budget and financial plans

Business licenses

Business licenses are needed for companies to operate in China. You will need to apply for a business license at the Administration of Industry and Commerce (AIC).

The information contained in the business license include:

  • 18-digit business registration number
  • Business scope
  • Company name
  • Date of establishment
  • License expiry date
  • Legal representative
  • Registered address
  • Registration bureau
  • Registered capital
  • Registration number
  • Type of entity

Accounting and tax compliance requirements for companies in China

Date of the financial year-end

The financial year-end of companies in China is the same as the calendar year, which starts on 1 January and ends on 31 December.

Safekeeping of proper accounts and records

Companies in China are required to keep accounting records in accordance with the accounting standards issued by the Ministry of Finance. All of the books, records and financial statements must be in Chinese and kept for 15 years. Companies must keep three types of accounting records:

  • General ledger and sub-ledgers
  • Journals
  • Supplementary memorandum records

Appointment of an auditor

The board of directors is responsible for appointing an auditor, and the financial statements must be audited by a Chinese-registered certified public accounting (CPA) firm.

Income tax return

Companies must file and pay income taxes monthly or quarterly within 15 days of the following month or quarter. They also need to file and settle their annual income tax return within five months after the end of the tax year.

Employment law in China

There are certain employment laws that foreign investors should consider when doing business in China.

These laws include:

Social security contribution in China

China’s social security system covers five types of benefits and a housing fund.

Benefit Employer contribution rate  Employee contribution rate
Pension 14% – 16% 8%
Medical expenses 10% 2%
Unemployment (up to 12 – 24 months of benefit in the case of redundancy) 0.5% – 0.8% 0.2% – 0.5%
Maternity  0.8% – 1% 0
Work-related injuries 0.5% – 2% 0
Housing funds (residents only) 5% – 12% 5% – 12%

Entitled leaves for employees in China

The number of leaves an employee is entitled to depend on the number of employment years.

Years of employment Entitled leaves
Less than one year No leave
1 – 10 years 5 days
11 – 20 years 10 days
Over 20 years 15 days

Sick leaves in China are given to employees who suffer from an illness or a non-work-related injury. Sick leaves in China are required to be paid for local and foreign employees. An employee is compensated at 60% to 100% of their normal salary during their sick leave. The percentage of compensation depends on the seniority of the employee, the city and its regulations.

Working period % of salary
Less than six months of sick leave
Less than two years 60%
Between 2 and 4 years 70%
Between 4 and 6 years 80%
Between 6 and 8 years 90%
More than eight years 100%
More than six months of sick leave
Less than one year 40%
Between 1 and 3 years 50%
Between 3 and 6 years 60%

The maximum sick leave is three months for employees with less than a 10-year employment history, while the maximum sick leave for employees with 20 years of work history is an unlimited paid leave.

Examples of common compliance risks

There are many examples of common compliance risks which should be carefully considered when active in China. Here are some of the most prominent examples.

Employment Taxes

Many companies traditionally sought to save on the cost of individual income taxes and social insurance contributions by paying part of salaries (and bonuses!) as reimbursements against valid legal invoices (fapiao). However, an employee complaint to the Labor Department or local tax officer may be sufficient to trigger an inspection, which could result in back-payments as well as late fees and fines. If the amounts of evaded taxes are large enough, these practices could even lead to criminal liability (though this is not common).


Corporate Taxes

Recently, some companies were pursued by a local district tax office in Shanghai for failure to pay withholding taxes on intercompany expenses booked in the previous year. Tax offices are improving their systems, and many are becoming more assertive at initiating inspections and monitoring compliance. Campaigns focusing on certain kinds of activities (in 2014: affiliated party transactions) are causing havoc to companies that do not strictly play by the rules.

Tax Evasion and Bribery (Commercial and Official)

Some companies manage to receive income off the books and then use some of these funds to pay illegal commissions (kickbacks) to promote sales, win projects or obtain licenses. Not only does this practice expose the company and its managers to liability for accounting fraud and tax evasion, but it can also result in administrative, civil and criminal liabilities for commercial or official bribery under PRC laws. Even in industries where such practices are common, especially foreign businesses may be the first to get caught – with life-altering consequences for the business and the involved managers.

Business Scope Restrictions

China continues to restrict foreign investment in certain sectors or subjects businesses to special licenses that are difficult to obtain. Examples in the service industry are recruitment (joint ventures only, unless the investor is CEPA qualified), labour dispatch (license difficult to obtain), legal services (closed to foreign investment), accounting and auditing (joint ventures only), as well as certain forms of education (subject to restrictions or licensing). Many foreign investors avoid such restrictions by establishing a general consultancy WFOE. But this exposes the business and could lead to fines and even revocation of the business license. As part of a long-term strategy, foreign investors should also consider alternatives such as making the extra effort to obtain the required licenses, relocating to a pilot area that allows this business (e.g. the Shanghai Free Trade Zone), using a VIE (Variable Interest Entity) structure or entering into a joint venture with a local partner. 

Future of compliance in China: Social Credit System

The future of compliance in China has already been announced through the introduction of the Social Credit System (SCS). The SCS is a system designed to measure individuals’ compliance, companies, and government entities. For business entities, the Chinese Government envisions the SCS to promote self-control through fear of unfavourable conditions. 

The SCS can be seen as a big data initiative, connecting the dots between data already in possession of the Chinese government. Such data includes whether all due taxes have been paid, whether organizations have all relevant licenses to operate, or whether the company has been fined for employment infringements. Based on these combined metrics, the government might impose unfavourable conditions, leading to a market disadvantage compared to competitors. 


All companies have sets of compliance requirements they must follow. Failure to meet these requirements may negatively impact the company, which may also lead to potential legal and administrative risks in the future.

Acclime will help you navigate through all kinds of difficulties you may face. To ensure you have satisfied all corporate compliance requirements for China companies, we recommend engaging with Acclime’s services. Feel free to contact us with questions!

Chinese fapiao (legal invoices) and trends in digitisation

In January 2021, over 25 regions entered China’s pilot program for digital special VAT fapiao’s, or e-fapiao. What started as a trial in Ningbo during the second half of 2020 was rapidly expanded towards other areas of China. Although currently still in its rollout phase, this development will significantly impact companies throughout China. This article will shortly review the e-fapiao and its benefits.

What is a fapiao?

A fapiao is a Chinese document used for registering the generation of revenue and VAT, i.e., a receipt mentioning the services sold, to whom it is sold, and the VAT rate. All Chinese business entities are obliged to issue these documents to their customers in China for payments received.

This document is printed on special paper that is provided by the State Tax Administration provides. Companies (incl. a foreign-invested company) can purchase the paper from their local tax bureau. Restrictions apply on the amount of fapiao that can be purchased as a means of supervision by the tax office.

The fapiao are always numbered and company specific. Typically, a printed fapiao has two or three layers. One layer is for internal bookkeeping, and other layers are given to the customer. Every month a company should declare the amount of fapiao issued at the tax bureau. The fapiao is one required document for cost-recognition of expenses within China, as it represents VAT paid by the customer and proves the official circulation of the transaction. A foreign-invested company must require its suppliers to provide a fapiao, and also print fapiao for its customers in China.

There are two types of fapiao in China:

  • General VAT fapiao: a type of fapiao in which the issued VAT cannot be deducted. This type of fapiao has already been digitalized and is often seen in restaurants, taxi’s or in e-commerce transactions.
  • Special VAT fapiao: these are fapiao issued when providing (taxable) services or goods. Special VAT fapiao can be used for VAT deductions.

How is the e-fapiao different?

The special VAT digital fapiao, or e-fapiao, is currently still implemented on a voluntary basis and can be used as an alternative to the printed version. As its name suggests, it is no longer a printed paper fapiao to deliver to customers. Indeed, after issued E-fapiao, customers can receive it by email or QR code then print it on A4 paper by themselves. Although the procedure is entirely digital, all data still needs to be added manually to the document. It is expected that the system will be rolled out nationally in the future and replace the current paper documents.

For a company in a pilot zone to start issuing e-fapiao, it needs to complete an application first. The company will receive a special token from the bureau after which it can log in to the online platform to issue the e-fapiao. Restrictions such as on the maximum value of one fapiao remain in place. Naturally, the company needs to be a general taxpayer to qualify. Before a company can issue e-fapiao, it needs to apply first at their local tax bureau. Restrictions such as on the maximum value of one fapiao remain in place.

One can check the validity of e-fapiao online on the local tax website. The website for Beijing can be found here.

What are the benefits of e-fapiao?

The national introduction of e-fapiao will result in a decrease in the workload that is required to ensure financial compliance. For example, checking the validity of fapiao will become easier, as one can check this online on the local tax website. However, a file management system for e-fapiao needs to be established. In terms of current bookkeeping and accounting regulations, little will change.

Anyone operating a company in China knows how much paperwork and administration is needed to stay compliant. A digital system will save a lot of paper documentation and thus is better for the environment.

Still, a streamlined process is needed to ensure that all parts can be digitalised, especially for audit purposes. Currently, general VAT e-fapiao must still be printed and included physically in the monthly accounting books.

Do you want to know if your company is eligible for the e-fapiao, or are you interested to learn more details regarding the application and usage of fapiao or e-fapiao? Acclime China is a regional expert provider of accounting, tax, consulting and corporate services and helps clients to seamlessly advance their businesses and interests in China. For more information about fapiao or other related matters, please contact Maxime at for a (digital!) meeting.

Celebrating our team’s achievements in 2020

China is one of the most difficult markets in the world to navigate as an international company, and so to have a knowledgable accounting & tax advisor can be the difference between success and failure. Therefore Acclime encourages their experts to always keep developing their knowledge and skill sets, to maximise their abilities to avoid or resolve any governmental and administrative compliance issues for our clients.

Our people determine the success of our business. We are grateful to have a team that is consistently developing themselves on so many different levels. Their hard work is essential to provide our clients with the high level of services which they expect from us.

We would like to take this opportunity to congratulate the following Finance and HR colleagues on their achievements in 2020.

Achievements of our finance experts

  • Congratulations to Ms. Gina Chen for qualifying as Certified Tax Agent
  • Congratulations to Ms. Catherine Shang for qualifying as Certified Public Accountant
  • Congratulations to Ms. April Wang for obtaining the Intermediate Accountant Certificate
  • Congratulations to Ms. Cecilia Yang for obtaining the Intermediate Accountant Certificate
  • Congratulations to Ms. Bess Zhang for obtaining the Junior Accountant Certificate

Achievements of our HR experts

  • Congratulations to Ms. Stella Zhou for obtaining the Certificate of Competences in Public Accounting for Global Accountants / Tax Agents / Finance Officers
  • Congratulations to Ms. Cloris Yang for obtaining the Intermediate Human Resource Manager Certificate, and the Certificate of Competences in Public Accounting for Global Accountants / Tax Agents / Finance Officers

Thank you all, for your ceaseless efforts to develop yourself.


Tax risks for expatriates when applying for tax-free rental benefits

Expatriates that live and work in China continue to enjoy certain privileges when it comes to individual income tax (IIT) on their income:

  • Compensation for rent
  • Relocation expenses
  • Language training
  • School fees
  • Home leave travel 

The Chinese government has created these benefits to establish a favourable work environment for foreigners, which has contributed significantly to the Chinese economy’s growth in recent decades. These benefits may lose effect at the end of 2021, but for now they remain an important part of an expatriate’s package in China.

Most foreign employees and their employers generally know which benefits are tax-deductible but are not always aware of the significant tax risks if some of these benefits are challenged. Failing to comply with the specific State Administration of Tax (SAT) regulations can lead to severe penalties and even legal prosecution.

Reasonableness of rent deductions 

In practice, misunderstandings often arise on how to apply the tax deductions correctly. The policies regarding the rental tax-deductions cause the most confusion; for example, we often read that the maximum deductible tax amount is 50% of the total salary, as long as the employee can provide a rental fapiao to their employer.

In fact, Chinese law does not actually set any limitation on the proportion of income that can be spent on tax-deductible rental; it only emphasises the need for reasonableness. Under the Notice of the State Administration of Taxation on Issues concerning the Implementation of an Individual Income Tax Levy or Exemption on Allowances of Foreign Individuals (Cai Shui Fa [1997] No. 054), expatriates may declare rental expenses not subject to IIT on the following conditions:

  • The compensation shall not be paid in cash (whether to the landlord or to the employee as reimbursement)
  • The rental amount must be reasonable and be supported by valid fapiao


Nowadays, an employer is left to make its own judgment on whether or not certain income should be subject to IIT, and to complete tax filings on time, and afterward the tax bureau can conduct random spot checks to confirm that all has been done correctly. If the tax bureau determines that the IIT filing for tax-free items does not comply with the law, then this is regarded as tax evasion and can have serious consequences.

The tax bureau will recover the unpaid tax from the employee and will usually charge a late fee of 0.05% per day. Moreover, the employee can be fined at between 50% and 500% of the unpaid tax; and as the withholding agent, the employer can be penalised at between 50% and 300% of the tax that it should have withheld. Moreover, if the employee has already left China or if the employer is deemed to have actively assisted the employee to avoid taxes, then the tax bureau may decided to charge the avoided tax, late fee and penalties directly to the employer.

Minimising risks

As the law states that tax-free rental income should be “reasonable”, the tax office has a lot of discretion to determine whether the employee and the company have acted so. As guidance, Shanghai tax bureaus will usually focus on the following when completing spot checks:

  • The lease agreement must be signed by the landlord that has the building property certificate, and the employee must actually live there. In the case of a sublease, a sublease agreement must be signed as endorsement
  • The rental should be paid directly to the landlord and the landlord must issue the fapiao (legal invoice) to the employee or the employer based on the lease agreement. If the landlord is an individual, they will need to go to the tax bureau where the property is located to issue the fapiao. All items in the fapiao should comply with current regulations.
  • The rental should be based on the lease agreement. The local tax bureau will also verify that the amount of rent is in line with local market prices.
  • Within the same period, a property can only be used by one person to claim the tax-free benefit. If there are multiple tenants simultaneously, then they may need to sign lease contracts with the landlord separately. The local tax bureau will then consider whether the total monthly rent is reasonable.
  • If necessary, the tax bureau will require other supporting documents and may ask to interview the landlord

Companies and individuals should always make sure that they comply with the requirements of their local tax bureau, and should always keep the above materials on file so that they can immediately respond to a tax bureau’s inspection. Moreover, where international companies outsource their IIT tax filing work to an external agent or corporate service provider, they should double-check that the service provider is familiar with the requirements for deductions and is able to stay up-to-date with all policy changes.

Opening a corporate bank account in China

Opening a corporate bank account in China has always been fairly straightforward. However, regulatory compliance at Chinese banks is becoming increasingly strict which is causing problems to foreign investors.


Chinese vs. Foreign Banks

Unlike in Hong Kong, the process of opening a bank account in the Chinese Mainland has always been relatively straightforward because of a lack of KYC and due diligence procedures. The big Chinese banks such as the Bank of China and the ICBC have welcomed foreign-invested companies to open their bank accounts at their branches, with very limited KYC procedures in place to review the actual business of these companies. The whole account opening process for a new foreign-invested enterprise (WFOE) usually takes 3-4 weeks.

This contrasts to opening a bank account at foreign-invested banks such as HSBC and Standard Chartered, which offer a full range of banking services but adhere to international standards when it comes to the intake of business. The Chinese branches of foreign banks have more elaborate compliance systems and relatively high KYC requirements and as a result, the process can take longer.


Procedural Challenges

Therefore the main challenge, especially in the case of Chinese banks, is procedural; and unfortunately this is becoming more difficult. Banks have always preferred the company’s legal representative to come to the bank in person to sign documents, but considering the hassle and potential delay when involving a non-Chinese legal representative residing abroad, most banks have traditionally been more flexible: the legal rep.’s original passport or a notarized / legalized copy has always been sufficient to convince a local branch to accept an application to open a new bank account.

In recent months, however, we have seen a change in this attitude. There are still bank branches that take a more flexible approach – accepting the original passport or in some cases, confirming the legal representative’s approval through a WeChat call or recording. These exceptions are often made based on the good relationship between a specific bank branch’s officers and the corporate service provider in charge of the bank opening process.

Under the guidance of internal policies from China’s central bank, however, the number of branches that dare to remain flexible is diminishing. In most cases, the legal representative is now required to come to visit the local branch in person.


Who to Appoint as Legal Representative?

Stricter banking rules present foreign investors with a dilemma. Since the legal representative position comes with much power (e.g. the legal rep. is legally permitted to represent the company towards third parties including the government), many international companies wisely prefer to appoint someone from headquarters in this position. But then:

  1. Travel to China is severely restricted due to Covid-19 regulations. Foreign executives can come to China but will need to complete a 2- or 3-week quarantine period which unfortunately cannot always be enjoyed in comfort. This means that in the end, appointing a foreign legal representative to a new subsidiary could delay the opening of the bank account and therefore the moment that the business can start operations.
  2. Where the Chinese business has a (senior) general manager, his or her appointment could be a good alternative. If not, then appointing a local staff member as the legal representative would be a practical solution but could put operational control in jeopardy. By giving such employee the “keys to the castle”, a company will take risks that normally would be deemed unacceptable.
  3. The concept of a “legal representative for hire” – e.g. appointing a third-party service provider in this position, is rare in China. First, a company cannot be appointed in this position; it must be a natural person. Second, the legal representative potentially bears administrative and even criminal liabilities in relation to the company’s operations, which for an outsider is generally not acceptable (especially for one that lives and works in China).



China is always changing, and the current trend is towards stricter compliance. This noticeably translates into stricter processes, including in relation to the opening of corporate bank accounts. Unfortunately, this also presents some foreign investors with new difficulties on how to arrange matters safely but efficiently. Foreign investors are recommended to plan ahead and seek appropriate advice from a service provider with the right level of experience.


Acclime China supports international investors on company set-up and provides administration services to Chinese subsidiaries of foreign companies, including accounting/tax filing, custodial services, payroll, and banking/treasury support. Acclime China cooperates closely with R&P China Lawyers, a leading Chinese law firm that supports international business in China. For more information on how Acclime China can help to manage, control and develop your business in China, please contact Maarten Roos at


A guide to registering a company in Hong Kong

According to the Doing Business 2019 Report published by the World Bank Group, Hong Kong ranks fourth among 190 economies in the world in terms of ease of doing business. Hong Kong’s unique geographical location as well as the minimum level of restrictions and bureaucracy are undoubtedly important factors for entrepreneurs expanding their businesses internationally.

Thanks to the extremely favourable tax policies, well-established legal system, and proximity to the huge market in the Mainland, Hong Kong has always been a popular registration destination for offshore companies around the world. This article will inform you about all relevant aspects that you need to know for the registration of a company in Hong Kong. Furthermore it will show you important details on how to maintain its status and stay compliant with the law.

Classifications of HK companies

There are multiple types of enterprises in Hong Kong, which are classified based on the legal liability of its owners. Each type of enterprise has different responsibilities and obligations; therefore, it is always advisable to choose the most suitable Hong Kong company type once you have decided to incorporate your company.

Based on the legal liability, there are two main categories of companies. First of all, there are the limited liability companies. As is the case with limited liability companies in most countries, the owners of a limited liability company in Hong Kong are not personally responsible for the debts of the company. Secondly, there are the unlimited liability companies. In these companies the owners are liable in case the company goes bankrupt. It is rare that investors and people coming to Hong Kong for business opt for an unlimited company, due to the protection concern of personal assets from business risks and liability, however we still wanted to include this option in this article to provide you with a good overview.

The limited companies are further classified to company limited by shares and company limited by guarantee. Furthermore, the company limited by shares can either be private limited company or public limited company, which are companies listed on the stock exchange. Most of the SMEs will choose private limited company registration, while public limited companies are often registered by medium to large scale businesses that decide to offer company’s shares to the public. As for company limited by guarantee, this form of company registration is commonly used for non-profit organisations.

Advantages of registering a Hong Kong company

The hassle-free setup

Compared to the abruptly changing rules and regulations, regional differences in rule enforcement, and the multi-bureau handled application process in Mainland China, setting up a Hong Kong company is an easy and straightforward process. Based on our past experience, opening a WFOE in mainland China often takes about 3-6 months, while the entire Hong Kong company incorporation process can be completed in about 2 weeks.

Below are the basic steps that need to be taken in order to set up a new company in Hong Kong:

  1. Preparation phase to determine the company name, legal structure, business scope
  2. Submission of registration documents submission and incorporation through the Hong Kong Companies Registry

The documents that need to be submitted are as follows:

  • Identification copies of the shareholders’ and directors’
  • Signed incorporation documents by the shareholders and directors
  • Proof of the Company address
  1. Opening a company bank account

The documentation and application process are straightforward. The company address acts as the address for receiving the company mails from the government and banks. If your company does not have any local business operations or employees in Hong Kong, then it is possible to get a registered office address through a secretarial firm for a small yearly fee. Moreover, there are very few restrictions regarding the business scope of companies in Hong Kong. Whereas in Mainland China there are the negative lists, which mandate the industries that foreigners may operate in. Furthermore, no capital verification is required for the registration of Hong Kong companies. Finally, throughout the entire registration process, the shareholder and director do not have to be present in Hong Kong. Something which saves a lot of travelling and money spent on plane tickets and hotel stays.

Favourable and simple tax system:

For enterprises in Hong Kong there are 3 main types of tax that apply. These are the profit tax, salaries tax, and property tax.

  • The profit tax is equivalent to the enterprise income tax in mainland China. The tax rate is 8.25% up to the first HKD 2 million of profit, and 16.5% for anything higher. In addition, Hong Kong adopts a territorial source principle of taxation. This means profits sourced elsewhere outside Hong Kong are not subject to Hong Kong profit tax.
  • Property owners are required to pay property tax on rental income of their properties in Hong Kong. The rates percentage charge is 15%.
  • Salaries tax is an income tax levied on an individual’s income, and the rates range from 2% to 17%. The taxpayers are individuals who derive income from their employment in Hong Kong.

In the meantime, Hong Kong companies have different tax reporting cycles compared Mainland to China. The first tax return will be issued by Inland Revenue Department only on the 18th month after the establishment of the company, and then once annually. Whereas in Mainland China taxes need to be filed on a quarterly or in some cases even monthly basis.

Hong Kong company maintenance and compliance

There are two annual maintenance practices of a Hong Kong company: Annual Inspection and Audits & Tax declaration:

Annual inspection

The Hong Kong business registration certificate, which is issued after the incorporation of a company, is only valid for one year. Therefore it needs to be replaced on the yearly basis through an annual inspection. The annual inspection document is required by the Hong Kong Companies Registry, and must state the relevant status of the company in the previous year, including the information of the shareholders, proportion of shares, operating status, etc. Fines are imposed if annual inspection document is not submitted in time.

More importantly, if a Hong Kong company does not file their annual inspection documents for several consecutive years, the company will be cancelled automatically. In this case, it will have negative consequences for any future HK-related activities of the directors and shareholders.

Audits & tax declaration

The annual financial statements of a Hong Kong limited company must be audited by a Hong Kong certified public accountant, and submitted with a profits tax return to the Hong Kong Inland Revenue Department for assessment. As for the tax declaration, if a Hong Kong company does not have any property, bank accounts, business operations, or employees in Hong Kong, then zero taxes can be declared.

After your Hong Kong company incorporation, you can still change the key personnel and objectives of your company, including but not limited to shareholder & director change, business scope change, company name change, etc. All of these changes must be conducted through applying for them at the relevant Hong Kong bureaus, and the process is relatively quick and easy. For instance, it only takes 5 working days to accomplish shareholder & director change.

Simplify your WFOE set-up

A wholly foreign-owned enterprise (WFOE), is the most common entity utilised by foreigners to do business in Mainland China. If you intend to enter the Chinese market with a physical entity, using a Hong Kong company as the parent company can save much time and effort. To register a WFOE in China all of the documents from outside of Mainland China need to be legalised and translated. This process often includes 3 steps. First of all, the incorporation documents must be notarised by a notary in respective country of the parent company. After the notarisation, the documents also need to be certified by the Chinese Embassy in respective country of the parent company. Finally, after all of this has been done the documents need to be shipped to Mainland China, where a Chinese translation must be made by an official translator.

This process is costly, long and can sometimes take months. However, a registration of a Hong Kong parent company only takes around 2 weeks. At the same time, the documents of the Hong Kong company are often in both languages (English and Chinese), which means the translation is no longer requested.

Apart from quicker set-up time, there are no foreign exchange controls in Hong Kong, and the free movement of funds and profits is not restricted. Therefore, with a Hong Kong company as shareholder, the profit distribution and money repatriation to the parent company will be much easier.

Closing remark

Over the years Acclime China has supported many clients with both the registration of a Hong Kong company, and the set-up of a WFOE in mainland China afterwards. Next to our registration and formation services in both Hong Kong and mainland China, Acclime provides our clients with hassle-free maintenance & compliance services under one roof, including Taxation, Accounting and auditing, and Company secretarial services, etc. As for cooperate related matters, often the rules & regulations itself are very clear, however, their actual enforcement and implementation can differ per case. If you would like to explore your Hong Kong company solution in greater depth, don’t hesitate to contact us.

China and HR compliance: Reviewing your employment situation

Not seldom, foreign-invested businesses are unaware of critical employment compliance requirements in China. It is a misconception that employees can be requested to work at any hour, whenever the business requires so, or that employees can be fired at will.

The opposite is the case. Chinese labour laws favour the employee quite significantly, while enforcement procedures can be easily and economically started by employees. Foreign-invested companies who treat their employees in China as if they were employed in their home country, may find themselves in precarious situations. Luckily, many problems can be avoided if the company has valid employment contracts, has adopted a staff handbook, and otherwise complies with the local laws and regulations . In this article, we will discuss the most critical points with regards to PRC Labour Law and Labour Contract Law compliance.

Employment contracts

Firstly, every employee must have signed a written employment contracts. The employment contracts shall not be in conflict with Chinese laws, so using standard contracts that are also used in the home jurisdiction is not advisable. These contracts will more likely than not contain plenty of clauses that will be non-compliant in China.

When drafting employment contracts, term and probation period are key considerations, and mandatory rules apply, and should not be violated. It speaks for itself that the employee must receive more than the minimum wage. The minimum wages differ from city to city and change very often, so it is crucial to stay on top of the recent developments. Therefore, pay special attention to the social insurance contribution levels, which are often – incompliantly – based on lower base levels than factually should apply.

Furthermore, it is worthwhile to protect the company’s IP and trade secrets in the employment contracts. Any successful company will have several trade secrets they do not want to see leaked. Therefore, a non-disclosure clause is an essential part of a good contract with key employees.

Besides, a non-compete clause can be useful. This will make sure (former) employees abstain from joining the competition. Please note, however, that the law on non-competes is quite extensive. The most important thing to consider is that the PRC law generally allows non-competes for a period up to two years, but that employers are required to pay the employee a monthly non-compete compensation during the non-compete term. This compensation shall be agreed between employer and employee, while failure to agree so in advance or before commencement, can lead to a court ruling that this compensation shall be set at 30% of the average remuneration during 12 months before termination.

Foreign employees

A company may be employing several foreigners, who are then subject to special regulations in the PRC and obtaining the necessary paperwork to obtain a work permit can be time-consuming. Besides having to comply with basic requirements like being in good health, and having no criminal record, foreigners may also be subject to specific local laws. For example, cities like Shanghai and Beijing require foreigners to have two years of relevant experience and at least a bachelor’s degree before allowing them to work there.

Pay extra attention to the fact that contracts with foreigners must comply with and be subject to PRC laws. This means that solely having contracts with foreign parent companies will not be deemed adequate for this purpose.

In most cities in China, foreign employees must contribute to social insurance funds. However, some cities have not yet implemented adequate government systems for this purpose, which could save considerable employer cost (f.i. Shanghai., for the time being).

Termination of contracts

Finally, a company must act carefully when terminating employment relationships with its employees. China does not allow for at-will employment for full-time employees, which means that an employee cannot be fired without due cause. Like many civil law jurisdictions, there must be legal grounds.

One of the leading legal grounds for lawful termination is a violation of company rules. For this purpose, companies should have duly implemented (following strict mandatory procedures) an internal document that sets out the company rules and regulations, usually referred to as a staff handbook or employee handbook. This should be a detailed document that describes as precise as possible how employees should behave. Without this document, it becomes challenging to fire or even sanction employees. Note that this document should best be written in Chinese, to avoid enforceability issues in local labor tribunals or courts.

If an employment relationship is unlawfully terminated, the employee can demand reinstatement or economic compensation that is double the severance in case of lawful termination (yes, in cases of lawful termination with notice, there is still severance pay). If legal grounds cannot be found, it is advisable to negotiate with the employee and try to reach a suitable solution for both parties to avoid legal proceedings.

Most of the time an adequate severance package will suffice, though if consensus cannot be reached, the employee may file a claim in labour arbitration. Employees whose contracts are not extended after an initial agreement term, are entitled to severance.

Severance is generally calculated on the basis of one month’s salary (“Severance Salary”) for each full year the employee has worked for the company. The Severance Salary means the average monthly remuneration of the employee during the last 12 months. The Severance Salary shall not exceed three times the local average monthly salary in the relevant city (around CNY 28,740 in Shanghai, at the time of issuance of this article in June 2021).

The above are general interpretations of the general laws and regulations, but their application on a local level can vary and should be consulted with employment law specialist.


It is common wisdom that prevention is better than the cure: compliance with employment provisions is thus crucial for running a successful business in China. Being compliant in the employment arena, will significantly decrease the cost of severance, labour disputes, and other employment issues. Especially in China, where labour laws change frequently and vary locally, this does require extra diligence when dealing with employees. For this reason, your employment situation shall best be reviewed annually.

All you need to know about HR compliance in China

As China transitions from an export-driven hub for cheap manufacturing to a domestic base of value-added consumerism, while at the same time experiencing a multi-year economic slowdown, companies are being forced to make difficult choices.

The Chinese government has significant influence on the process of firing workers through its numerous rules and regulations, and Chinese labour laws highly protect employees themselves. Therefore, the wrong approach by HR managers can lead to costly problems, such as workplace disruptions, labour disputes, and refusals from government officials to support a company in its hour of need.

Labour contract law of the PRC

Article 41 of the Chinese Labour Contract Law (amended 2012) details the laws around redundancy of employees for economic reasons. Employers can use this ground as long as they terminate either 10% or more of the total workforce, or at least 20 employees. To be eligible, employers are required by the law to meet one of the following specific conditions, which are meant to protect employees:

  • The company must have serious problems restricting its production or business
  • The economic circumstances on which the finalisation of a labour contract was based have undergone significant changes and, as a result thereof, the labour contract can no longer be performed
  • The company undergoes restructuring according to the requirements of the Enterprise Bankruptcy Law of the PRC
  • The company changes production, significant technological reform, or modification of mode of operation and, upon variation of labour contracts, there is still a need for cost-cutting

Qualification for economic redundancy

When downsizing on a large scale in China, companies need to follow a strict schedule as outlined below:

  1. Announce the situation to the relevant labour union, or all staff, 30 days in advance of the planned downsizing
  2. seek out the opinions of the labour union or the employees;
  3. implement a schedule for enacting the redundancy
  4. communicate the redundancy schedule to government labour administrative authorities
  5. and announce the formal program of economic redundancy to all staff, terminate labour contracts with laid-off staff, and settle their severance payments

The conditions of eligibility for executing an economic redundancy are very general. To minimise the risk that individual employees will challenge a redundancy programme in labour arbitration, it is critical to obtain support in advance from the supervising labour administrative authorities at a local level. In practice, many companies start with step four (above), and get an informal green-light to proceed. Also important to note are the regional differences in the local officials’ willingness to support mass layoffs; for example, Shanghai is unofficially known to be much more lenient and expeditious than Beijing.

Alternatives to economic redundancy

Where support is not forthcoming, an alternative approach may be considered. Companies may terminate not for economic redundancy but on other legal grounds, such as with mutual consent (subject to higher payments).

The most significant practical disadvantage to economic redundancy is that employees must be notified well in advance, which means that they have more opportunities to be disruptive to the business. Therefore, some companies choose to bypass the economic redundancy altogether, and directly negotiate a termination of the employment contract with employees – as a group or individually.

In any case, companies should expect heightened emotions involved in the process of terminating 20 or more people from the payroll. Security should be prepared (physical safety along with digital and cyber-related) and precautions taken well in advance of any announcement as upset employees may seize assets. A plan to approach key employees beforehand can lead to a smoother process.

What it means for HR professionals

Close coordination with staff – both the ones who will remain employed and those being terminated – will produce the smoothest-possible transition for restructuring. HR professionals should be sensitive to the following:

  • When terminated, employee livelihood is under threat. Before any steps are taken, employees should be categorised by job title, salary, and time spent with the company so that that correct calculations can be made on possible costs to the termination, especially with regards to severance packages.
  • The HR department is the first to employees and the last to see them on their way out. HR professionals should be prepared with the critical message and essential questions that need to be addressed.
  • Terminations should be done swiftly and be tightly managed, in a way that aligns with the urgency of change as well as the focus of the company.
  • Timing is essential in massive terminations. Often, companies give notice on a Friday, late in the day or before a holiday, believing that the staff will be in good spirits, and hence, less upset with the news. This is not always true. Moreover, disruptions during the weekend are less likely and not as intrusive.

Handling the remaining workforce

Seeing a large number of colleagues suddenly disappear may well affect the morale of the employees who still have jobs. Moreover, these employees may start to doubt their job security, fearing that the next round of terminations is just around the corner. The following are a few more ideas for managing the sentiment of those left standing:

  • Provide training that will fill the skills gaps left by those now gone
  • minimise the risk of burnout, so no one feels overwhelmed
  • boost morale, by proactively fielding questions and concerns
  • and set a solemn, respectful tone in the workplace immediately after the termination by not making any superfluous expenditures, such as having a party or redesigning the office


Companies need to prepare for the courses of action that proceed economic redundancy and implement plans and strategies that ensure smooth transitions from both a legal and a practical standpoint.

The golden rule for exploring China by businesses

The first thing a (foreign) company should do before even considering winning the affection of 1.3 billion potential Chinese consumers is making sure that you own or apply for the trademark right to use your name and brand in China.

In our practice, we have seen too much money wasted on buying such rights from people or companies who outsmarted the ‘new kids on the block’, often by maliciously registering ‘their’ trademarks.

Forgetting to register their brand is probably the most common mistake made by international companies entering the Chinese market. Ten years ago, this issue already caused big MNCs launching consumer products in China plenty of headaches. Newcomers seem not to have learned much from their predecessors seeing that the latest wave of foreign companies to entering China still often forget to register their names and brands – after which they turn to us to resolve this critical issue.

Naivety can be costly

Many still think that their status in the West and the fact that they have been around for many years will protect them in China. Others are under the impression that registering their name and brand in Europa or other countries will be sufficient to enjoy rights in China and legally conduct business. Unfortunately, this is rarely the case. This naivety is why we had seen many reputable companies having to pay up tens of thousands (and sometimes millions) of Euros, to obtain the right to use their ‘own’ brand in China after others managed to register it before they did.

Proper registration

Avoid this mistake! To enjoy the full trademark protection in China, you need to register the name of your business and the brands of products and services at the China Trademark Office (CTMO). We know dozens of companies that are currently active in China without having a proper registration.

Often, when they start working with partners, agents or distributors who they trust, only to find out that their Chinese partner has registered ‘their’ trademark in its name or that of a relative or third party, forcing their foreign counterpart to remain partnering with them. Things can even get crazier – and with even more damaging results. We have seen cases in which a Chinese partner sued the gullible international business for using its ‘own’ name in China. Our advice is, therefore: never leave the registration in the hands of your Chinese counterpart. Do it yourself, ASAP!

First to file

Bear in mind that PRC trademark law is based on the ‘first to file’ principle. This means that the party that files first is likely to be accepted for registration. A local application in China is recommended since it only costs a few hundred Euros, and takes around 9-12 months (international application often 15+ months).

In case your desired mark is registered by another company, your case may fall under on one of three most common grounds for appeal:

  • This registration has been done in bad faith, by someone (a supplier, distributor) of whom you can prove they knew your company, name and brand before filing
  • If the trademark has been registered for more than three years, it may be cancelled if the holder of the mark could not prove useful in the past three years
  • The brand was (very!) well-known in China before the trademark holder applied for the mark

Case: wine

There are some well-known cases concerning this subject matter. Castel, an international wine brand, had not registered its Chinese character name “Ca Si Te” when they started selling and becoming known under this name in China (somebody else did though!).

Castel, perhaps unaware of the registration or its importance back in the days, continued its wine marketing and sales under the Chinese name in China. The Chinese owner of “Ka Si Te” was awarded around EUR 3.5 million in damages even in court of appeal (though the Supreme Court ultimately overturned this into the insignificant amount of around EUR 65,000). Another famous case involved Apple who settled for an amount over USD 60 million to retrieve the right to use the word “iPad” in China, because somebody got to the registration office before them, sued them for trademark infringement!

Pulling tricks

No matter how questionable the ethics of Chinese businesspeople pulling tricks like this are, it is a matter of perspective. Are they so different from the people that registered domain names during the internet hype 20 years ago in Europe and the US? Not all motives are about money:

  • For some parties, it is just their creative way of making sure you will remain to conduct business with them in the future.
  • Some companies may randomly apply for the same or similar name and want to use this brand.
  • Finally, one should understand why enjoying protection in China for ‘your’ brand is not – and should not be – a given. Let’s say your Dutch brand is called Vale, imagine how many brands in South America may be called Vale (means ‘okay’ in Spanish!), and engage in the same products or services as you do.

Which of these companies should enjoy complete protection in China? Yours? But why? Difficult to determine, right? Well then perhaps awarding it to the first-to-file isn’t such a wrong solution after all…

Find a professional advisor to find out who is behind the application, and determine a trademark strategy together, which can include legal action, negotiations or purchasing.

Do not contact the other party yourself until you obtain proper advice. If a trademark squatter registered in bad faith, they may want to either secure your business as a distributor/supplier, or they did it to sell it to you at a premium.

In the case of the former, you can benefit from legal support to get the upper hand in negotiations, rather than giving in to their demands.

In case of the latter, if legal action does not bring a result or even before taking action, you may want to try to purchase the trademark as the fastest and most secure way to obtain the trademark.

Though if they find out you as an international brand are interested in this trademark, they will presume you are planning to do business in China, and the asking price will rise sharply. Using an undisclosed party to secure the mark is potentially a viable option to lower the purchasing price.

Consider how quickly you want to enter the Chinese market, and how strongly you need trademark protection when entering. If you can afford to wait 1-3 years, legal action may be a first way to try to obtain the trademark at reasonable cost, but with a lengthy and still costly process and without any guarantees. If you want to conduct business sooner rather than later, you may have to negotiate a deal and purchase the trademark.

Why protecting your trademarks is a top priority for doing business in China

Protecting your trademarks in China can be tricky, mainly where legal provisions differ from those in your legal environment. But this does not mean that you should refrain from bringing your trademarks to China.

When evaluating the opportunities for doing business in China, most entrepreneurs are more or less aware of the fact that the company’s intellectual property rights (IPR) will be exposed to an unstable legal environment that undergoes considerable changes to this day.

One may find that the level of legal protection offered to IPR in case a dispute arises is different from—and, admittedly, in some instances not entirely on par with—the standard of your jurisdiction. The stories where an “innocent” western company had its trademarks infringed upon in China and consequently learned its lesson the hard way, are all too familiar in western news headlines. Hence, brand owners must consider the available legal options available to pre-emotively strengthen positions and therefore optimise the opportunity to defend IPR from would-be competitors and IPR pirates.

Ultimately, not only does trademark infringement cause financial losses to the trademark owner, but the entire reputation of a brand could be severely damaged due to the low quality of ubiquitous and inferior counterfeits sold in China for a lower price. Or whenever the infringer engages in competitive business but delivers a low level of service quality, respectively.

As unbelievable as it may sound that a consumer would expect cheap counterfeits to match the original product in terms of quality, many examples prove otherwise. In one case, several enraged Chinese consumers contacted the hotline of a foreign manufacturer of golf clubs to make use of “their” warranty after their product broke after just a few months of use. Unbeknownst to the consumers, however, they had purchased inferior counterfeit products.

It is irrelevant if this disappointment goes on account of the consumers’ ignorance – the reputation of the brand suffers nonetheless, and the loser is the trademarks’ owner. It goes without saying that in an even worse scenario, sub-standard fake products like food, beverages and pharmaceuticals may even be harmful to the consumer’s health.

Together with the economic growth, middle-class Chinese consumers have developed certain expectations in terms of product quality, not to mention a level of brand consciousness which is at least on par with, if not exceeding, their Western counterparts. Consequently, protecting the image of your products and services by registering your trademarks is one of the critical aspects to success in the Chinese market.

Registering your trademarks in China

The first step to prevent competitors and counterfeiters from illegally using your trademarks is to identify the trademarks relevant for your business activities and register them in China to secure the exclusive rights.

China, as a member of the WTO, is obligated to ensure that applicable Chinese laws comply with the TRIPS agreement. Furthermore, China has signed several treaties on the international protection of IPR with the World Intellectual Property Organization (WIPO).

However, trademarks registered in one member state are not recognized by another member state. China applies a ‘first-to-file system’: the owner of the trademark shall be the first (legal) person to file its application with the Trademark Office of the State Administration for Industry and Commerce (SAIC). Upon approval, the owner of the trademark enjoys exclusive usage rights in the respective trademark class applied for, and they can enjoin other parties from violation of their rights.

In other words, only the owner of a trademark registered in China can institute administrative or legal enforcement actions against the violator.

This system has led to many cases where the ’rightful’ owner of the trademark found that another individual or entity had already registered their trademark in China.

In that case, the trademark’s owner in other jurisdictions may be prevented from using this trademark in China! Suppose you find yourself in such a scenario. In that case, you should immediately consult your lawyer to discuss whether an appeal with the Trademark Review and Adjudication Board (TRAB) can successfully reclaim your rights.

Besides the registration of the internationally used trademark, an appropriate Chinese translation should be considered, and the application must be filed separately. There are two different approaches to this task:

One possibility is to translate the meaning of the trademark (e.g., Germany’s Volkswagen translates directly to the Chinese equivalent of ‘Da Zhong Qi Che’), while the other is to make a phonetic transcription, preferably with a positive Chinese connotation (e.g. Coca Cola translates to ‘Ke Kou Ke Le’, roughly meaning “delicious and joyful”).

While this procedure may be uncommon or unheard of in Western countries (as usually the same brand name in roman letters is registered as a trademark), it can help to positively influence the image of the trademark, especially when a smart and elegant translation is created to appeal to the Chinese customer.

Moreover, considering that most Chinese consumers (and managers of companies, where the product or service is sold to businesses) do not speak English, it is perhaps not surprising that most foreign brands in China are known by their Chinese names – which therefore should be protected.

Navigation through the broad scope of enforcement methods in China requires knowledge and a sense for the reasonableness of means

Unfortunately, even registered trademarks are far from being safe from infringement. As one marketing expert put it, if your product is not being counterfeited in China, you did a lousy job. Enforcement may be unavoidable depending on the individual case and if the infringement interferes with the company’s business interest.

Several channels can be employed to protect trademarks and IPR in general in China, but which enforcement method is the most suitable for the case highly depends on the risks associated with it, as well as on the infringement and the opponent.

Sometimes the infringement will not inflict real losses to the rights-holder (e.g. when upscale counterfeit commodities are sold on streets and markets in underdeveloped regions with no target market for the product), and it should be deliberated about whether the extent of infringement is worth any legal action.

Not least factors like local protection and corruption of authorities should not be underestimated in the whole process. However, when the infringement directly competes with the plaintiff’s business or the reputation of the trademark may suffer, the situation is different. Therefore it is always inevitable to evaluate the case with a competent legal expert.

Trademark protection – enforcement methods demand letters

Preparing a demand letter with your lawyer sends a signal to the infringer that you are determined to take legal steps if they fail to cease the act of violation immediately. Depending on the circumstances, the infringer may conclude that the illegal business activities are not worth the struggle with courts and legal expenses as well as the publicity of the trial. On the other hand, a demand letter has no legal force. On the contrary, in some cases, it may even complicate the collection of evidence for a civil action since the infringer has been given enough time to “miraculously” let the evidence disappear.


The General Administration of Customs (GAC) offers two methods of protection from the import and export of fake commodities: A trademark owner may request the GAC to retain a shipment if the products to be shipped are suspected of violating IPR. A security deposit and relevant documents proving the applicant to be the rightful owner of the trademark must be submitted to customs. If it is determined that its IPR have indeed been infringed upon, Chinese law provides for seizure and destruction of the merchandise.

Alternatively, you may preemptively register and submit relevant information regarding the IPR to be protected with Chinese customs. Under this condition, customs officials can hold back shipments of counterfeit goods during spot checks, and report to the trademark owner who can then prepare for action. Therefore it is always advisable to register the trademarks with the GAC, as it simplifies the examination procedures and is the best way to circumcise export of counterfeit goods out of China.

Administrative authorities

In China, the holder of rights can apply to administrative authorities to carry out raids to confiscate counterfeits. Several different authorities are entitled to perform raids and seizures, depending on the kind of IPR involved.

If this method is considered, legal counsel should be retained to determine which administrative authority should be contacted, and to coordinate with such authority to ensure optimum results. Raids are arranged relatively quickly and can lead to quick results (i.e., immediate seizure of fake goods, destruction of equipment used to produce counterfeits, and imposition of a fine).

In some cases, however, the fines may be insufficient to de-motivate the infringers, in which case administrative actions will be inadequate as an effective long-term deterrent. Moreover, the plaintiff will neither achieve any compensation for the damages suffered nor for the legal and enforcement fees, as the imposed fines are administrative only. However, an administrative action is easy and fast to arrange to take immediate action. It can serve as a good and safe way to secure inculcator evidence, which then can be used in litigation.

Civil action

Another way to combat trademark infringement is to institute legal proceedings with the people’s courts. While some western companies may be reluctant to rely on the reasoning and impartiality of Chinese courts, it should be noted that China established special IPR tribunals in most of the higher people’s courts and the developed, wealthier regions.

Nonetheless, litigation demands for careful preparation, as the burden of proof lies on the plaintiff, and the legal system does not provide for discovery. Therefore it is essential to gather and provide the proper evidence and documentation such as notarised samples of the counterfeit products (oral testimonies are generally not sufficient). If the plaintiff wins the case, the compensation awarded is usually low compared to western standards.

Compensation is solely related to the losses suffered from the infringing act, while the imposition of punitive damages as an effective deterrent is unknown in Chinese law. Moreover, it is usually challenging to prove for the plaintiff to deliver an accurate estimation of the suffered damages. In this case, the Chinese court may impose a sum that it considers reasonable, and within a statutory limit of RMB 500,000 for trademark infringement.

In rare cases, the courts may evoke the infringer’s business license, but this probably does not impress a smaller company that does not have to worry about its reputation. Sometimes, the infringers just set up another business next door and continue with the infringement.

For a company of a decent size or with other business activities (besides the infringing ones) though, this could cause considerable damage. In any case, even though many foreign companies may find the statutory compensation to be insufficient concerning the scope of infringement, it should be noted that it may be deterrent enough to hamper the infringer’s activities since they often operate on a small scale.

Furthermore, it is possible to identify the infringer’s assets and bank accounts and then apply the court to freeze them while simultaneously filing the lawsuit. This makes sure the infringer does not have the chance to transfer their assets to defy any order from the court, and thus increases the likelihood that the plaintiff receives some compensation.

Criminal action

Criminal complaints should be filed with the Public Security Bureau (PSB). At least, in theory, the PSB then reports all criminally relevant cases for prosecution to the people’s courts. As powerful a deterrent a criminal suit may be (the maximum penalty for the unauthorised use of registered trademarks in severe cases amounts to 7 years imprisonment), the current liability thresholds for criminal prosecution are subject to harsh international critics.

The criminal liability thresholds are calculated on a base of illegal turnover and income. However, due to the high thresholds and the significantly low prices of counterfeit goods, criminal relevance is seldom given. Nevertheless, successful criminal action is gratifying and provides for the most robust deterrence, as in many cases infringers not only may be sentenced to up to three years in prison or be fined, but the holder of rights also can simultaneously file a civil lawsuit to obtain compensation.


Branding becomes increasingly essential in the world’s biggest consumer market, and one must make use of all available legal means to prevent others from illegal use of your property, the consequences of which could severely damage your brand’s reputation. To achieve the best possible degree of protection, you should register trademarks with the Chinese authorities as early as possible, and ideally BEFORE you intend to enter the Chinese market.

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