A real-life scenario: The owner of a foreign trade factory set his sights on the Southeast Asian market, quickly registered a company in Singapore, rented an office, hired local employees, and then transferred funds from his domestic account to the Singaporean company as startup capital—only to have the money blocked by the bank. The bank requested proof of ODI filing, leaving the owner completely baffled: ”I’m registering an overseas company—do I really need to file for that?”

This was one of the most typical ”failures” in overseas expansion in 2026. Many people assume that simply registering an overseas company and transferring funds abroad is all it takes. In reality, when mainland Chinese enterprises or individuals invest overseas—which involves the outflow of funds—they are required in the vast majority of cases to complete ODI (Overseas Direct Investment) filing, which is jointly regulated by the National Development and Reform Commission, the Ministry of Commerce, and the State Administration of Foreign Exchange. Failure to complete ODI filing leads to immediate consequences: funds cannot be sent abroad (banks will block the transfer), profits and principal cannot be repatriated in compliance with regulations, and penalties will be imposed (illegal capital outflows face fines and a record of the violation).

Why has going global become increasingly popular in recent years, yet there have been more and more cases where companies have been held up by ODI regulations? On the one hand, the restructuring of global supply chains has made it a consensus that ”if you don’t go global, you’re out of the game”; on the other hand, in March 2026, the People’s Bank of China and the State Administration of Foreign Exchange jointly issued the ”Administrative Measures for Overseas Lending by Domestic Enterprises,” which brought all overseas lending by domestic enterprises—whether in RMB or foreign currency—under a unified macroprudential regulatory framework. As a result of these standardized regulations, scrutiny of capital outflow channels has become much more rigorous. Enterprises that comply with ODI filing requirements enjoy policy benefits; those attempting to circumvent regulations and “go global through indirect channels” face sharply increased risks.

When it comes to cross-border investment compliance, every step—from planning the strategy to completing the filing process—involves specialized details. Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), the Cayman Islands, and more. We also offer one-stop corporate services such as annual reviews and audits, bookkeeping and tax filing, tax compliance, business registration changes, bank account openings, ODI and FDI filings, and other corporate services; Hong Kong residency applications, renewals, and permanent residency services; Singapore Employment Pass (EP) application services; and cross-border e-commerce mentoring and managed operations—all as part of our one-stop service. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

I. What is ODI Filing? Who Needs to File?

ODI (Overseas Direct Investment) filing refers to the process by which domestic enterprises establish businesses overseas or acquire interests in existing overseas enterprises through means such as establishing new entities, mergers and acquisitions, or equity participation; submit the necessary filings or applications for approval to the National Development and Reform Commission and the Ministry of Commerce in accordance with regulations; and complete foreign exchange registration with the State Administration of Foreign Exchange.

Typical scenarios requiring ODI filing include:

• Establishing an Overseas Subsidiary: Establish subsidiaries or branch offices in Singapore, Vietnam, Thailand, Malaysia, and other locations;
• Cross-border mergers and acquisitions: Acquiring equity interests and assets in foreign companies;
• Overseas Reinvestment: Investing in third countries through intermediary structures such as Hong Kong entities;
• Overseas Real Estate/Equity Investments: Domestic funds are transferred abroad under the guise of direct investment.

The decision on whether to proceed hinges on two key factors:Does the source of funds originate from within the country?,Whether an Interest in an Overseas Entity Has Been Formed. Whenever domestic funds are transferred overseas to make foreign investments, the filing procedure is generally unavoidable. Individuals who invest overseas through informal channels in small, incremental amounts also face foreign exchange control risks.

II. The Complete ODI Filing Process: Three Departments, One Set of Guidelines

Step 1: Filing with/Approval by the National Development and Reform Commission. Depending on the investment amount and industry, submit an application for filing or approval of overseas investment projects to the National or provincial Development and Reform Commission to obtain a project code and a filing notification.

Step 2: File a report with the Commerce Department. File a report with the commerce authorities to register the overseas investment and obtain the “Certificate of Overseas Investment for Enterprises.” This step verifies the legal status of both the investing entity and the overseas enterprise.

Step 3: Foreign Exchange Registration. Present the filing documents issued by the National Development and Reform Commission and the Ministry of Commerce to a bank or the State Administration of Foreign Exchange to complete the foreign exchange registration for overseas direct investment and open a dedicated ODI account; only then can you legally purchase and transfer foreign currency overseas.

The core principle of the entire process is ”file for approval first, then export”—if the order is reversed, the entire process is nullified. It is also important to note that ODI filing forCompliance Records of InvestorsNote: Companies that have been listed as having operational irregularities in recent years, have a history of serious violations, or have been penalized by the State Administration of Foreign Exchange are highly likely to have their filing applications rejected.

III. Common Reasons for Rejection: Why Is Your Filing Always Being Rejected?

Many companies get tripped up at the filing stage, and the most common reasons for rejection boil down to the following:

1. The logic of the argument does not hold. The overseas company’s business description, source of funds, and investment objectives were vague, and the National Development and Reform Commission could not discern the ”actual overseas investment scenario,” so it rejected the application outright.

2. The entity does not meet the required qualifications. Domestic entities that have been in operation for too short a period, have no actual business operations, or have been listed as ”abnormal” are the main problem areas in the filing process. Regulatory authorities require “investment entities with genuine operational capabilities.”

3. The path design is unreasonable. Multi-tier architectures, association arrangements lacking genuine business logic, and intermediate architectures that are clearly designed as workarounds are likely to result in requests for additional clarification or even rejection.

4. Poor time management. The filing process typically takes several months, and many companies only realize they won’t be able to complete the filing in time after they’ve ”signed the contract and are in a rush to make the payment,” forcing them to adjust their transaction structure and incurring heavy losses.

IV. How to Choose the Entity: How to Structure Company Registration in Singapore and Southeast Asia?

ODI registration is just one aspect of ”fund compliance” when expanding overseas; the other aspect is ”entity compliance”—the jurisdiction in which an overseas company is registered directly determines its subsequent tax burden, operational costs, and compliance costs.

Singaporean: As a financial hub in Asia, Singapore has a standard corporate income tax rate of 17%, a comprehensive network of tax treaties, and a strong international reputation, making it an ideal location for regional headquarters, holding platforms, and financial centers. The accompanying Employment Pass (EP)—which allows entrepreneurs to secure both residency and business establishment by applying for an EP—makes Singapore a popular choice for entrepreneurs expanding overseas. However, the costs of registration and operation in Singapore are relatively high, making it more suitable for companies of a certain size.

Emerging markets in Southeast Asia (Vietnam, Thailand, Malaysia, Indonesia, etc.): With low labor costs and a rapidly growing market, these countries are well-suited for manufacturing relocation and local market expansion. Vietnam has a corporate income tax rate of 20% and offers multiple tax incentives, while Thailand and Malaysia each have different foreign ownership restrictions and market access rules—registration requirements, tax filing procedures, and labor laws vary significantly from country to country, necessitating country-by-country planning.

fact: Low tax rates (two-tier capital gains tax system), no foreign exchange controls, and alignment with international standards, making it suitable as a trade settlement center and cross-border financial hub (for more details, see the Qicaiying series of articles on offshore tax exemptions).

The most common structure in practice is:Hong Kong/Singapore as a holding and settlement platform + a Southeast Asian entity as the operating entity + a mainland entity to complete ODI filing——Each layer of the three-tier structure has its own specific role. Building this entire framework involves multiple steps, including ODI filing, overseas company registration, opening bank accounts, tax registration, auditing, and tax filing.

Qicaiying’s overseas expansion services provide a one-stop solution for this entire process: ODI filing (pre-investment path mapping, preparation of filing materials, and filing guidance), Overseas company registration (in popular regions such as Singapore, Southeast Asia, Japan, South Korea, Europe, and the U.S.), guidance on opening overseas bank accounts, VAT and tax compliance support, and Singapore Employment Pass (EP) application services. From the compliant outflow of domestic funds to the establishment and operation of overseas entities, and on to supporting arrangements for personnel status, we help companies expanding overseas avoid detours and minimize trial-and-error costs. Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the U.S., Japan, South Korea, Southeast Asia, Singapore, the BVI, the Cayman Islands, and other locations, as well as annual company audits, bookkeeping and tax filing, tax compliance, information changes, bank account opening, ODI filing, FDI filing, and other corporate services; Hong Kong residency applications, renewals, and permanent residency services; Singapore EP application services; and cross-border e-commerce support and agency operations. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

V. Three Pieces of Advice for Entrepreneurs Preparing to Expand Overseas

First, plan your path, then take the first step. Expanding overseas isn’t about ”registering a company first and figuring things out later”; rather, you need to first clarify: how funds will be transferred abroad (ODI), how the corporate structure will be set up (holding/operating/settlement entities), how taxes will be handled (cross-border pricing and filing), and how personnel will be staffed (EP/work visas)— —Only by planning these four aspects simultaneously can you avoid the awkward situation of ”having registered the company but being unable to transfer funds.”

Second, factor compliance costs into investment calculations. ODI filing, local company maintenance, auditing and tax filing, and annual reviews and inspections—these are not optional; they are the basic costs of expanding overseas. The essence of compliance investments is to provide insurance for the entire overseas expansion structure.

Third, find partners who understand the ”end-to-end” process. The pitfalls in the process of expanding overseas often don’t lie in any single step, but rather at the junctions between steps: the transition from filing for record to opening a bank account, from company registration to tax registration, and from the company to the EP. A professional partner capable of covering the entire process is more valuable than ten individual service providers combined.

Conclusion: In the second half of the global expansion journey, compliance infrastructure is what matters most

In the first half of expanding overseas, it’s all about courage; in the second half, it’s all about compliance. ODI filing, overseas entities, cross-border capital flows, and tax structures—these ”invisible infrastructure” elements determine how far and how steadily your overseas business can grow.

Don’t let ”being unable to send money abroad” be the first chapter of your story about expanding overseas.

Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), the Cayman Islands, and other locations, as well as services such as annual company audits, bookkeeping and tax filing, tax compliance, information updates, bank account opening, ODI filing, FDI filing, and other corporate services; Hong Kong residency application, renewal, and permanent residency services; Singapore EP application services; and one-stop services such as cross-border e-commerce coaching and managed operations. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add me on WeChat: Qicaiyingjituan).

The world is vast, and the journey to go global is a long one—if you take the first step right, every step that follows will be much easier.