The competent commerce departments of all provinces, autonomous regions, municipalities directly under the Central Government and the Xinjiang Production and Construction Corp, the securities regulatory bureaus of China Securities Regulatory Commission (hereinafter referred to as the CSRC) in all regions, Shanghai Stock Exchange, Shenzhen Stock Exchange and China Securities Depository and Clearing Corporation Limited:
With a view to carrying into effect the requirements of the Guiding Opinions of China Securities Regulatory Commission on the Share Trading Reform of Listed Companies (Zheng Jian Fa [2005] No. 80), promoting the share trading reform in an active and stable manner, pursuant to the relevant laws and regulations on foreign investment as well as the relevant provisions on foreign-funded joint stock companies, we hereby notify the relevant issues concerning the administration of foreign investment in the share trading reform as follows:
I. The procedures for change of equity as involved in the share trading reform of an A-share listed company that holds the approval certificate of foreign-funded enterprises (hereinafter referred to as a foreign-funded listed company)
The board of directors of a foreign-funded listed company shall directly file its share trading reform scheme with the Ministry of Commerce for record within 2 workdays after the notice on holding the relevant shareholders' meeting is issued. After a share trading reform scheme is adopted by resolution at the relevant shareholders' meeting, the board of directors of a foreign-funded listed company shall, within 1 workday, report the following documents through the competent commerce department of a province, autonomous region, municipality directly under the Central Government, city specifically designated in the state plan or the Xinjiang Production and Construction Corp (hereinafter referred to as the provincial competent commerce department ):
(1) An Application;
(2) Voting result at the relevant shareholders' meeting;
(3) A statement on the share trading reform;
(4) The sponsor's opinions;
(5) The legal opinions;
(6) If any state share or state corporation share is involved, the approval documents of the administrative department of state-owned asset administration on the disposal of the relevant non-tradable shares shall be submitted;
(7) If a pledge is set on any share to be disposed of, the letter of agreement produced by the relevant pledgee shall be submitted; and
(8) Other document as prescribed by any law or regulation.
The provincial competent commerce department shall, within 2 workdays as of the date of receipt of the application documents, transfer them to the Ministry of Commerce, which will solicit the opinions of the CSRC within 2 workdays as of the date of receipt of the documents. The CSRC shall make a confirmation of no demurral in writing to the Ministry of Commerce within 2 workdays. The Ministry of Commerce shall, within 5 workdays, make a reply on the change of equity of a foreign-funded listed company according to law.
II. The enterprise nature of and enterprise treatment for a foreign-funded listed company after a share trading reform
(1) After a share trading reform scheme of a foreign-funded listed company is carried out, within the term wherein the holders of the original foreign corporate shares promise not to sell any share (hereinafter referred to as the time limit for not selling shares), a listed company will continue to hold the approval certificate of foreign-funded enterprises and enjoy the preferential treatment as given to foreign-funded enterprises. As is the general principle, any change in proportion of foreign shares as incurred from the share trading reform will not have any impact on the relevant existing policies of the listed company.
(2) If, upon the expiration of the time limit for not selling shares, the holders of the original foreign corporate shares sell no shares, the listed company will continue to hold the approval certificate of foreign-funded enterprises and enjoy the preferential treatment as given to foreign-funded enterprises. Or
(3) If, upon the expiration of the time limit for not selling shares, any shareholder of the original foreign corporate shares sells any share thereof:
a) Where the proportion of foreign shares of a listed company is no less than 25% after the selling of foreign shares, the listed company will continue to hold the approval certificate of foreign-funded enterprises and enjoy the preferential treatment as given to foreign-funded enterprises.
b) Where the proportion of foreign shares of a listed company is no less than10% but nor more than 25%, as is incurred from selling of the original foreign shares by any holder, the listed company will continue to hold the approval certificate of foreign-funded enterprises. For the preferential treatment as given to foreign-funded enterprises that the company has enjoyed, the relevant formalities shall be handled in accordance with the relevant provisions of such departments of taxation, Customs and foreign exchange administration. Or
c) Where the proportion of foreign shares of a listed company is less than 10%, as is incurred from selling of the original foreign shares by any holder, the listed company shall, within 3 workdays, go through the relevant alteration formalities with the relevant departments such as the Ministry of Commerce and the administrative department for industry and commerce and may not hold the approval certificate of foreign-funded enterprises any more.
III. The strategic investment made by overseas investors in listed companies
According to the Guiding Opinions of China Securities Regulatory Commission on the Share Trading Reform of Listed Companies and the relevant provisions on merger and acquisition by foreign capital, an overseas investor is allowed to make strategic investment in a listed company. Where a listed that has gone through a share trading reform needs to attract any strategic investment from abroad for the implementation of its development strategy, upon the approval of the relevant departments such as the Ministry of Commerce, an overseas strategic investor may make purchase of shares of A-share of a listed company and promise to hold a certain proportion (as is a general principle, the International Monetary Fund's definition on foreign direct investment shall be referred to; in the case of any clear provision thereon, it shall prevail). As to the procedures for examination and approval of the purchase of shares of a listed company by an overseas investor as well as the management of share accounts, the measures for the administration thereof shall be separately formulated by the Ministry of Commerce and the CSRC.
IV. An A-share listed company with H-share or B-share that holds the approval certificate of foreign-funded enterprises may continue to hold the approval certificate of foreign-funded enterprises after the share trading reform.
V. After the share trading reform, a foreign-funded listed company shall report any change of H-share proportion to the Ministry of Commerce as required. The China Securities Depository and Clearing Corporation Limited shall provide the relevant services of data inquiry according to the requirements of the Ministry of Commerce.
VI. Any change of equities of a foreign-funded listed company that hasn't gone through the share trading reform for the time being shall be handled in light of the relevant provisions in force.
VII. The power to interpret the present Circular shall reside in the Ministry of Commerce and the CSRC.
VIII. The present Circular shall go into effect as of the date of promulgation.
杨春宝一级律师简介
杨春宝一级律师,大成上海高级合伙人、资本市场部主任、国资基金研究中心主任,大成中国区私募基金专业带头人、科技与文化法律研究中心联合牵头人。执业30余年,长期从事私募基金、投融资、并购重组法律服务,尤其对对赌研究颇深且具有非常丰富的实战经验,并专注于金融机构股权投资业务。2004年起多次入选The Legal 500"私募基金"和"公司与商业"等境内外各类律师榜单,代理的中国法院首例适用外国法律审理外国公司的董事损害小股东权益纠纷案入选上海高院发布的《上海法院域外法查明典型案例》和威科先行"要案头条"。入选上海涉外法律人才库、上海市司法局鼎新法治人才库、上海国有企业改制法律顾问团,具有上市公司独立董事任职资格,系多家知名高校的兼职教授或兼职研究生导师及上海市商务委跨国经营人才培训班讲师。出版《私募股权投资基金风险防控操作实务》等16本投融资法律专著。了解更多常见法律问题
股东之间发生股权纠纷,应通过什么途径解决?
股东之间发生股权纠纷,解决途径包括:1)协商谈判——双方就股权回购、转让价格、退出机制等达成和解协议,降低诉讼成本和时间;2)公司内部调解——依据公司章程或股东协议约定,通过董事会或监事会调解;3)仲裁或诉讼——向人民法院提起股东代表诉讼、股权回购诉讼或公司解散诉讼。杨春宝律师团队在处理股东权益纠纷方面具有丰富经验,代理过多起股权纠纷案件,包括上海某知名英语培训公司小股东股权回购纠纷仲裁案(北京仲裁委)等。更多请见 https://shanghaiiplawyer.com/shanghai-equity-structure-lawyer/
小股东权益被侵害如何维权?
小股东权益被侵害时,可采取的维权措施包括:1)行使知情权——依据《公司法》第33条,要求查阅公司会计账簿、股东会会议记录等文件;2)行使分红权——请求公司分配利润,若公司无正当理由拒绝分配利润,可提起诉讼;3)行使临时股东会召集权——持有10%以上表决权的股东可提议召开临时股东会;4)提起股东代表诉讼——当公司董事、监事、高级管理人员损害公司利益时,股东可代位提起诉讼;5)请求公司回购股权——对公司合并、分立、转让主要财产等决议投反对票的股东,可请求公司按照合理价格回购股权。建议及时咨询专业股权律师,通过法律途径维护合法权益。
股权转让有哪些法律程序?
股权转让需遵循以下法律程序:1)内部优先购买权程序——向其他股东书面通知转让事项,其他股东在30日内回复是否行使优先购买权;2)签署股权转让协议——明确转让标的、价格、付款方式、交割条件、陈述与保证等条款;3)修改股东名册和公司章程——公司应将受让方记载于股东名册,并相应修改公司章程;4)办理工商变更登记——向市场监督管理局提交变更申请,完成股权变更登记。涉及国有股权需经国有资产监督管理机构审批,涉及外商投资需符合《外商投资法》相关规定。杨律师团队可提供股权转让全流程法律服务。
以上内容仅供参考,不构成法律意见。如需专业法律服务,请联系杨春宝一级律师:chambers.yang@dentons.cn



