The NDRC registration / filing regime – An Update

In our Client Alert on 16 June 2016, we mentioned the recent practice of the NDRC requiring “little red chips” to make a registration/filing with the NDRC prior to the pricing of an offshore debt bond/loan.

Since then we have seen a number of developments and examples which reflect the NDRC’s latest thinking. In this Client Alert, we provide a brief summary of the key practice points. We start off by revisiting the more established position with regards to onshore issuers and "traditional red chips" before turning to "little red chips" and other scenarios where the application of the NDRC registration/filing requirements is less clear.

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We would welcome any queries on these latest NDRC developments. Please feel free to contact any of your usual Linklaters contacts if you wish to discuss further.