China Capital Controls Overview

$50K

Annual SAFE Quota

QDII

Institutional Channel

HK

Routing Hub

10%

Treaty Dividend Rate

China has strict capital controls enforced by SAFE (State Administration of Foreign Exchange). Violations can result in criminal penalties in China.

The $50,000 Annual SAFE Quota

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Each Chinese citizen may convert up to USD $50,000 equivalent per calendar year through the Individual Foreign Exchange Quota system. This is the most common legal pathway for smaller investments.

What You Can Do

  • Convert RMB to USD at any bank
  • Wire funds abroad for permitted purposes
  • Use for education, travel, or investment
  • Quota resets each January 1

Limitations

  • Cannot split among family members illegally
  • Cannot use for capital account purposes (real estate)
  • Banks may ask for purpose documentation
  • Increased scrutiny for full quota usage
The "ant moving" strategy (splitting large amounts among many people) is illegal and increasingly detected by Chinese authorities.

Permitted vs Restricted Uses

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Permitted (Current Account) Restricted (Capital Account)
Education expenses Real estate investment
Travel expenses Securities investment
Medical treatment abroad Business capital investment
Family support (with documentation) Insurance investment products
Small purchases online Loan repayments abroad

Capital account transactions require SAFE approval regardless of amount.

QDII Investment Channel

Qualified Domestic Institutional Investor

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QDII allows Chinese residents to invest in overseas securities through licensed Chinese financial institutions. This is the primary legal channel for securities investment.

QDII Advantages

  • Fully legal and compliant
  • Access to US stocks and bonds
  • No individual quota concerns
  • Professional management options

Limitations

  • Limited to approved products
  • Higher fees than direct investment
  • Quota availability varies
  • Cannot invest in real estate
Major Chinese banks and securities firms offer QDII products investing in US ETFs and stocks.

Hong Kong as Investment Hub

Using Hong Kong for USA Investment

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Hong Kong has no capital controls and serves as a critical hub for Greater China investment into the USA. However, moving money from mainland China to Hong Kong is still subject to SAFE regulations.

Legal Pathways to HK

  • Business income earned in HK
  • HK employment income
  • Cross-border Wealth Management Connect (limited)
  • Legitimate trade payments

From HK to USA

  • No restrictions on amount
  • Full currency convertibility
  • HK banks experienced with US wires
  • Can form HK company as holding entity

See our Hong Kong Investment Guide for detailed HK structuring strategies.

Cross-Border Wealth Management Connect

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The Southbound scheme allows Greater Bay Area residents to invest in HK wealth management products through designated banks.

Current Limits

  • Individual quota: RMB 1.5 million
  • Aggregate quota: RMB 150 billion
  • Only eligible products
  • Closed-loop system

Eligible Investors

  • Greater Bay Area residents
  • 2-year investment experience
  • Income or asset requirements
  • Bank account in GBA

Offshore Investment Structures

VIE and WFOE Structures

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Chinese businesses with offshore operations may have legitimate offshore funds that can be invested in the USA without mainland capital controls applying.

Common Structures

  • Cayman Islands holding company
  • BVI intermediate entity
  • Hong Kong operating company
  • VIE structure for Chinese operations

USA Investment Path

  • Offshore entity invests directly
  • Forms US LLC or corporation
  • Opens US bank account
  • No SAFE approval needed
Offshore structures must be set up for legitimate business purposes. Structures solely to evade capital controls are illegal.

ODI (Outbound Direct Investment) Approval

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Chinese companies can apply for ODI approval to make direct investments abroad. This is the legitimate pathway for large-scale business investment.

ODI Requirements

  • NDRC approval (project level)
  • MOFCOM filing or approval
  • SAFE registration for forex
  • Post-investment reporting

Approval Timeline

  • Under $300M: Filing only (faster)
  • Over $300M: Full approval required
  • Sensitive industries: Extra scrutiny
  • Timeline: 2-6 months typically

US-China Tax Treaty

Treaty Benefits for Chinese Investors

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The 1984 US-China Tax Treaty provides reduced withholding rates for qualified residents of China.

Income Type Standard Rate Treaty Rate
Dividends (10%+ ownership) 30% 10%
Dividends (under 10%) 30% 10%
Interest 30% 10%
Royalties 30% 10%
Capital Gains (real estate) FIRPTA 15% FIRPTA applies
File IRS Form W-8BEN with Chinese tax residency certificate to claim treaty benefits.

Recommended Entity Structures

For Real Estate Investment

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Simple Structure

  • Wyoming or Delaware LLC
  • Owned directly by Chinese individual
  • EIN and US bank account
  • FIRPTA withholding applies on sale

Offshore Structure

  • HK or BVI holding company
  • Owns US LLC
  • May reduce estate tax exposure
  • More complex reporting

For Business Investment

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E-2 Visa Structure

  • China not eligible directly
  • Consider Grenada citizenship + E-2
  • Or L-1 intracompany transfer
  • EB-5 for permanent residency

Corporate Structure

  • Delaware C-Corp for growth
  • LLC for pass-through taxation
  • Consider double tax implications
  • Transfer pricing documentation

Scam Protection for Chinese Investors

Common Scams Targeting Chinese Investors

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Chinese investors seeking to move money abroad are prime targets for sophisticated scams. Be extremely cautious.

Red Flags

  • Promises to "move money secretly"
  • Underground banking (fei qian) offers
  • WeChat investment groups
  • Guaranteed high returns
  • Pressure to act quickly

Safe Practices

  • Only use licensed banks
  • Verify all professionals
  • Never share banking credentials
  • Get everything in writing
  • Consult licensed attorney
Read our Chinese Scam Protection Guide before sending any money abroad.

OFAC Sanctions Compliance

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All transfers to the USA are screened against OFAC sanctions lists. Chinese nationals and companies may face additional scrutiny due to certain sector-specific sanctions.

Review our OFAC Sanctions Screening Guide for compliance requirements.