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For non-Chinese companies, one of the main challenges for offering equity-based awards to employees in the People's Republic of China ("PRC") are the restrictions and requirements imposed by the Central State Administration of Foreign Exchange ("Central SAFE"). Although the requirements are better understood and the filing processes have become more streamlined since the restrictions were first imposed in 2007, registering with a local SAFE office and complying with the ongoing requirements continues to be a time-consuming undertaking.

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