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Is it difficult for a wholly foreign-owned enterprise to apply for a foreign debt registration certificate when borrowing from an overseas parent company?
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Detailed rules for the implementation of foreign debt registration of the State Administration of Foreign Exchange

Article 1 These Detailed Rules are formulated for the implementation of the Interim Provisions on Statistical Monitoring of Foreign Debt (hereinafter referred to as the Provisions).

Article 2 Foreign debt refers to all debts that are directly borrowed from abroad and need to be borne in foreign currency with contractual repayment obligations. The specific contents include:

1. Loans from international financial organizations: refers to loans provided by international and regional financial organizations such as the International Monetary Fund, the World Bank, the Asian Development Bank and the United Nations Fund for Agricultural Development;

Loans from foreign governments: official development assistance loans provided by foreign governments to China;

Loans from foreign banks and non-bank financial institutions: refers to loans provided by overseas banks, other non-bank financial institutions and syndicated organizations;

4. Buyer's credit: refers to the loan provided by a foreign bank issuing export credit to the import department or bank of China to purchase equipment from the exporting country;

5. Loans from foreign enterprises: refers to loans provided by overseas non-financial institutions;

6. Issuance of foreign currency bonds: refers to bonds issued by domestic institutions in overseas capital markets, and the face value of bonds is expressed in foreign currency;

7. International financial leasing: refers to the financial leasing provided by overseas leasing institutions to domestic institutions;

8. Deferred payment: refers to the financing provided by foreign exporters to domestic import departments, and the import enterprises will pay loans abroad three months after the imported goods enter the country;

9. Debt directly repaid in cash in compensation trade: refers to the debt agreed in the compensation trade contract to be repaid in cash or changed from commodity repayment to cash repayment upon approval for some reason, including services compensated by export income;

10. Other forms of external debt, including:

(1) Foreign currency deposits of overseas institutions or individuals absorbed by domestic financial institutions;

(2) Loans from domestic enterprises (including foreign-invested enterprises) to domestic foreign-funded or Sino-foreign joint venture banks. In addition, the following situations are also regarded as foreign debts:

(1) Debts that need to be actually repaid by domestic institutions when overseas registered institutions are transferred to China in various forms;

(2) Foreign debts of overseas institutions that are not registered overseas;