Because of the inconsistency between the flow of funds and the flow of goods in offshore transfer transactions, relevant departments have buckled each other in response to inquiries. For example, in a case, "a company is registered in a free trade zone, and the company has a cross-border trade. The goods are bought from France and sold directly to Hong Kong. The sales are all denominated in foreign currencies. At present, the company has directly picked up the goods from France at the request of  customers, and has received foreign exchange from Hong Kong customers. At the same time, it can provide upstream and downstream sales contracts, invoices and corresponding customs clearance materials for French export declarations. The question is “Is it possible to go through the foreign exchange payment procedures? ” So, for this case and similar cases, can offshore transfer trade be done? What are the key points of compliance in foreign exchange? Please refer to the following questions and answers.

Q:	What are the laws and regulations based on?
A:	"Notice of the State Administration of Foreign Exchange on Further Promoting Trade and Investment Facilitation and Improving Authenticity Examination" (Huifa [2016] No. 7) "Notice of the State Administration of Foreign Exchange on Issues Concerning the Printing and Distributing of Regulations on Foreign Exchange Administration of Trade in Goods" (Huifa [2012] No. 38)
Q:	What are the requirements for banks to handle offshore transfer transactions?
A:	The same offshore transfer transaction should be settled in the same currency (foreign currency or RMB) at the same bank outlet. Contracts, invoices, true and effective transportation documents, bill of lading warehouse receipts and other cargo rights certificates shall be provided to ensure the authenticity, compliance and rationality of the transaction.
Q:	Which companies cannot handle offshore resale transactions?
A:	Enterprises that are classified as Class B in the foreign exchange management of trade in goods are temporarily suspended from handling foreign exchange receipts and payments for offshore transfer transactions.
Q:	Do companies need to report separately to the Administration of Foreign Exchange?
A:	The enterprise shall, within 30 days from the actual occurrence of the import and export of goods or the receipt and payment of foreign exchange, report to the local foreign exchange bureau through the monitoring system the corresponding estimated foreign exchange receipt and payment or import and export date and other information: Businesses in which the interval between receipts and payments of re-export trade under the same contract exceeds 90 days (not included) and the amount of foreign exchange received under the item of first payment and then payment or the amount of foreign exchange payment under the first payment and then payment item exceeds the equivalent of US$500,000 (excluding).
Q:	Is it necessary to consider related compliance issues of customs?
A:	For offshore resale transactions, because the goods are always abroad, companies do not need to consider the customs compliance issues of China Customs in actual operations, and China Customs does not supervise such businesses.