[Content Abstract]:Since 2016,Chinese enterprises have been issuing bonds abroad in full swing.Based on the experience of long-term overseas bond projects undertaken by Chinese enterprises,the author intends to explore the focus of legal services provided by domestic lawyers in overseas bond issuance from the perspective of the concept of overseas bonds,pre issuance procedures,issuing entities,bond ratings,issuance rules and methods,capital repatriation,issuance period,and other key points,With a view to providing better legal services for lawyers in such projects in the future.

[Key words]:Lawyer services for overseas bond issuance     

In recent years,with the"going global"of Chinese enterprises and the implementation of the"the Belt and Road"national strategy,many domestic enterprises have gone to Hong Kong,Singapore and other overseas securities exchanges to issue US dollar bonds for different purposes,either to finance or to show themselves to the outside world.The hot wave of domestic enterprises going overseas to issue US dollar bonds has lasted for nearly two years.At the same time,in 2018,some restricted industries such as real estate companies and local government financing platforms will continue to be blocked from domestic financing,so the boom in overseas US dollar bond issuance may still continue.Based on the case of US dollar bond issuance undertaken by the author,I would like to analyze some major concerns of US dollar bond issuance by domestic enterprises from the perspective of domestic lawyers.

1、Pre process for overseas bond issuance

According to the provisions of Paragraph 1 of Article 1 of the"Notice of the National Development and Reform Commission on Promoting the Reform of the Management and Registration System for the Issuance of Foreign Debt by Enterprises"(hereinafter referred to as the"Notice")(FGWZ[2015]No.2044),foreign debt refers to debt instruments with a term of more than 1 year that are borrowed overseas by domestic enterprises and their controlled overseas enterprises or subsidiaries,denominated in local currency or foreign currency,and subject to agreed repayment of principal and interest,including bonds issued overseas Medium and long-term international commercial loans,etc.

At the same time,in accordance with the provisions of Paragraph 3 of Article 1 of the"Notice",enterprises that issue foreign debts must apply to the National Development and Reform Commission(hereinafter referred to as the National Development and Reform Commission)for filing and registration procedures in advance,and submit issuance information to the National Development and Reform Commission within 10 working days after the end of each issue.

In June 2016,in accordance with the Reply of the National Development and Reform Commission on the Scale Arrangement of Pilot Provinces and Cities for Foreign Debt Management Reform in 2016(FGWZ[2016]No.1139),the control authority for domestic enterprises to borrow medium and long-term international commercial loans and issue bonds overseas was delegated to six provincial and municipal development and reform commissions,including Tianjin,Shanghai,Guangdong,Fujian,Xiamen,and Shenzhen,within the scale of foreign debt control approved by the National Development and Reform Commission,Local enterprises registered within their jurisdiction that issue bonds overseas and borrow medium and long-term international commercial loans shall be responsible for issuing the"Registration Certificate for Enterprise Issuance of Foreign Debt"by their provincial and municipal development and reform commissions.In June of the same year,the National Development and Reform Commission selected 21 enterprises,including the China Development Bank,the Export-Import Bank,the five major state-owned banks,China Life Insurance,Huarong Assets,Cinda Assets,CICC,CITIC Securities,ICBC Leasing,etc.,CITIC Group,Sinopec,China Merchants Group,CSCEC,China Railway Construction,Sichuan Development,Huawei Investment Holdings,and HNA Group,to carry out the pilot reform of foreign debt scale management in 2016,Within the annual scale of foreign debt,21 pilot enterprises can independently choose the issuance window,issue in installments and batches,and no prior registration is required.After the issuance is completed,the issuance information will be submitted in a timely manner.

According to the above regulations,except for the enterprises under the jurisdiction of the foreign debt management reform pilot area and 21 pilot enterprises,if a domestic enterprise indirectly borrows foreign debt through an overseas wholly-owned subsidiary or a domestic parent company directly borrows foreign debt,and the term exceeds one year,the nature of the debt belongs to the foreign debt specified in the Notice,then the borrowing must apply to the National Development and Reform Commission for filing and registration procedures in advance.

The author has conducted a detailed analysis of the political risks,legal risks,and legal liabilities arising from the failure of domestic enterprises to file their overseas borrowings with the National Development and Reform Commission in advance for a period of more than one year,as described in the previous article"Legal Considerations on Filing Overseas Borrowings in Advance".

2、Analysis of Elements of Overseas Bond Issuance

(1)Issuer

When undertaking overseas bond issuance business as a domestic lawyer,the author,through sorting out materials and communicating with domestic and foreign investment banking institutions,found that in 2017,Chinese dollar bonds showed explosive growth,with a total financing amount of approximately$237.9 billion.In 2018,under downward pressure from the domestic economic environment,the total financing amount was approximately$185.6 billion,and the issuance scale decreased.By the end of 2018,the stock size of the Chinese dollar bond market was approximately 772.6 billion US dollars,of which investment grade bonds were approximately 519.4 billion US dollars,accounting for 67.23%,and high yield(including unrated)bonds were approximately 253.2 billion US dollars,accounting for 32.77%.

Meanwhile,according to the website"Wall Street Traders",in January 2019,36 Chinese issuers priced 47 US dollar denominated bonds in the offshore market,with a total principal amount of US$18.095 billion.Among them,Chengdu Economic Development and Investment Corporation,Jizhong Energy Group,and Luoyang Molybdenum Industry issued US dollar denominated bonds for the first time.From the perspective of circulation,it has significantly increased compared to December 2018(+50.5%),but it is significantly lower than the same period last year(January 2018 circulation was 21.8 billion US dollars,YoY-17%).Although the overall circulation was lower than that of the same period last year,the circulation of the real estate sector reached$12.125 billion,the highest monthly circulation in history.

Through the analysis of the above materials,it is not difficult to find that the issuers of domestic foreign debt are generally concentrated in the top 100 domestic real estate development enterprises,medium and large state-owned enterprises(including market-oriented local government financing platform companies),and medium and large private enterprises(domestic A-share listed companies or overseas main board listed companies).If the aforementioned overseas bond issuers have issued bond products in China,they are more likely to be favored by overseas investors.

(2)The Impact of"666"Document on Issuing Entities

On June 6,2019,the General Office of the National Development and Reform Commission(hereinafter referred to as the"National Development and Reform Commission")issued the"Notice on the Relevant Requirements for Filing and Registration of Applications for Issuing Foreign Debt to Local State-owned Enterprises"(FGBWZ[2019]No.666)(hereinafter referred to as the"666 Document"),which was released on the official website on June 13.Document No.666 is another important notice issued by the National Development and Reform Commission to regulate foreign debt risks and local debt risks,following the"Notice of the National Development and Reform Commission on Promoting the Reform of the Registration System for Enterprises to Issue Foreign Debt"(FGWZ[2015]No.2044)and the"Notice of the Ministry of Finance of the National Development and Reform Commission on Improving the Market Restraint Mechanism and Strictly Preventing Foreign Debt Risks and Local Government Debt Risks"(FGWZ[2018]No.706).

Article 5 of Circular 666 stipulates that local state-owned enterprises that assume the financing function of local governments can only issue foreign debts to repay medium-and long-term foreign debts due within the next year.The author believes that it contains two meanings:First,for local state-owned enterprises that have currently obtained the Registration Certificate for Filing Foreign Debt Borrowing by Enterprises and issued overseas bonds,their raised funds can be used according to the purposes stated in the submitted application documents and the Registration Certificate for Filing Foreign Debt Borrowing by Enterprises,without complying with the restrictions on the use of funds stated in Article 5 of Circular 666.2、Whether the"local state-owned enterprises undertaking the financing function of local governments"can successfully pass the registration of the National Development and Reform Commission and issue new overseas bonds.

Regarding the second meaning contained in Article 5 of Circular 666,the author believes that up to now,there is no unified legal definition of"local government financing platform".The"Notice on Issues Related to Strengthening the Management of Local Government Financing Platform Companies"(GF[2010]No.19)clarifies the definition of urban investment platform for the first time,that is,local governments and their departments and institutions through financial allocations or injection of land Equity and other assets are established as economic entities that undertake the financing functions of government investment projects and have independent legal personality.However,urban investment platforms cannot be directly equivalent to local government financing platforms.Various regulatory departments,such as the China Banking and Insurance Regulatory Commission,the Ministry of Finance,and the National Development and Reform Commission,have adopted different recognition standards.The Ministry of Finance emphasizes the public welfare nature and non marketization,The CBRC's caliber emphasizes that local governments should fund the establishment and bear joint repayment responsibilities.In combination with the purpose of preventing medium and long-term foreign debt risks and local government implicit debt risks set forth in Circular 666,the author believes that in addition to the list of local government financing platforms issued by the China Banking and Insurance Regulatory Commission as one of the important criteria for intermediary institutions and enterprises to determine whether they are"government financing platforms",the Ministry of Finance's determination of"local government financing platforms"based on its own work functions is more in line with the purpose of Circular 666.At the same time,the National Development and Reform Commission replaced the concept of"government financing platforms"with the concept of"local state-owned enterprises undertaking local government financing functions"in Document No.666.Therefore,the author believes that its scope should not be limited to the list of local government financing platforms issued by the CBRC,A comprehensive judgment should be made based on the relevant provisions of the CBRC and the Ministry of Finance on"public welfare nature,non marketization,establishment funded by local governments,and joint and several repayment responsibilities".In view of the fact that many local state-owned enterprises have issued announcements in recent years that they will no longer assume the financing functions of local governments,we suggest that,if necessary,before applying for overseas bonds to the National Development and Reform Commission,whether local state-owned enterprises can also seek written opinions from the local banking and insurance regulatory authorities and the Ministry of Finance on whether they have local government financing functions,in order to smoothly promote the work of overseas bonds.

(3)Bond rating

Generally speaking,issuing bonds domestically requires a credit rating.Similarly,issuing US dollar bonds publicly overseas also requires a credit rating,and at least two international rating companies are entrusted to perform the rating.If private placement is adopted,the international credit rating of bonds may not be required.However,the credit rating results given by domestic rating agencies cannot be directly adopted when issuing overseas bonds.Moody's,S&P,and Fitch,the three internationally recognized rating agencies,use the same methodology and model when evaluating a Chinese company and an American company,which enables the rating results to be recognized by overseas investors.While the domestic rating scale represents the ranking of the issuer's domestic credit status in China,it must refer to the risk factors of the macro industry in China,so there may be differences between domestic and international ratings.For example,Gansu Province Highway Aviation Tourism Investment Group Co.,Ltd.has a US$500 million three-year US dollar bond with an overseas rating of BBB-and a coupon of 3%/year,while its domestic credit rating is AAA;Jiangsu Fangyang Group Co.,Ltd.has a US$200 million three-year US dollar bond with an overseas rating of BB and a coupon of 5.35%/year,while its domestic credit rating at the time of issuing US dollar bonds is AA;Wuhan Metro Group Co.,Ltd.has a US$290 million three-year US dollar bond with an overseas rating of A and a coupon of 2.375%per year,and its domestic credit rating is AAA.

Judging from the ratings of overseas bonds of Chinese enterprises,about 90%of their claims are not rated,and it is a common phenomenon that bonds are not rated,including companies such as COFCO and Huawei,which have issued unrated bonds.There are three possible reasons behind this:Firstly,Chinese non-financial enterprises often use SPVs as issuers,and domestic and foreign banks or domestic group companies need to provide guarantees,so there are more SPVs that do not carry out ratings as issuers;Secondly,in overseas RMB bond issuance,due to the relatively abundant offshore RMB fund pool,investors have low sensitivity to ratings;Third,rating can shorten the process of debt issuance,reduce information disclosure,and enhance the convenience of issuers to independently and reasonably arrange the timing of debt issuance.

If investment grade bonds with an international rating of BBB-or above(Moody's rating is Baa3)are more favored by overseas investors,the interest rate level will generally be lower than the domestic bond interest rate for the same period,while speculative grade bonds,i.e.bonds with an international rating of BBB-or below,generally have higher interest rates than domestic bond interest rates for the same period.

(4)Issuance rules and methods

There are two main ways to issue US dollar denominated bonds in the overseas bond capital market:registered issuance and private placement(such as Rule 144A issuance).The issuer is required to be a company that regularly discloses in the U.S.bond market due to its registration with the U.S.Securities Regulatory Commission.The disclosure requirements are strict and must meet certain conditions.Therefore,the common issuance method of overseas U.S.dollar bonds is private placement,including RegS and 144A."They are a regulation in the United States Securities Act that allows issuers to issue securities directly to qualified institutional investors without registration.The main difference between the two is that RegS is issued to investors outside the United States,while 144A is also issued to qualified investors within the United States.".Due to the fact that the objects of issuance under Rule 144A include investors in the United States,generally issues greater than$500 million and with a term longer than 10 years will adopt 144A issuance to ensure the success of the issuance.However,under the 144A issuance method,the audited financial statements used must meet the 135 day requirement.

The issuance methods of overseas bonds are divided into direct issuance and indirect issuance.The implication mainly depends on whether it is issued directly by financing entities or through special purpose companies(SPVs)established overseas,with cross-border guarantees provided by the parent company.If direct financing is adopted,it is issued by domestic entities,and there is no need to increase credit.Its entity rating and debt rating are equal.If indirect issuance is adopted,it is through a special purpose company(SPV)established overseas as the issuer,and the domestic parent company provides credit enhancement.The credit enhancement will also distinguish between cross-border guarantees or Keepwell Agreements+Equity Interest Purchase UNDERTAKING(EIPU).

From a legal perspective,the maintenance agreement is not a guarantee agreement,but a contractual obligation between a domestic parent company and an overseas subsidiary.According to the agreement,the parent company provides support to overseas subsidiaries,ensuring to international investors that the issuer of US dollar bonds will maintain appropriate equity and liquidity,and will not go bankrupt.EIPU is a supplement to the maintenance agreement.In the EIPU,the parent company will commit to purchasing the assets of overseas subsidiaries in China.This increases the channels for overseas issuers to obtain funds from domestic parent companies.In the event of a bond default,the parent company will purchase assets from the overseas issuer and its domestic subsidiaries,thereby paying the overseas issuer sufficient funds to cover all of the issuer's debt liabilities.This also reduces the concern of international investors that they will not be able to claim domestic assets from the issuer.

If the credit enhancement method in indirect issuance adopts domestic guarantee and foreign loan,the domestic parent company provides cross-border guarantee to the special purpose company(SPV)established overseas,and the SPV serves as the main issuer of US dollar bonds.On February 11,2018,the National Development and Reform Commission issued the"Directory of Sensitive Industries for Overseas Investment(2018 Edition)",in which Article 4(6)stipulates that the establishment of equity investment funds or investment platforms without specific industrial projects overseas is a restriction on overseas investment.Based on the case studies of some local government financing platforms that have undertaken to issue overseas bonds,the author finds that local government financing platforms mostly adopt the establishment of shell companies in Hong Kong,China,and some shell companies in Hong Kong,China establish offshore companies in the Cayman Islands or the British Virgin Islands to issue overseas bonds.According to the relevant provisions of the"Directory of Sensitive Industries for Overseas Investment(2018 Edition)",if the issuance of overseas bonds continues to be carried out through the establishment of a domestic shell company,the author is skeptical whether it can be approved when reporting to the domestic commercial department for domestic approval.If the commercial department strictly controls the establishment of investment platforms without specific industrial projects overseas,the current issuance of overseas bonds may prefer to adopt the direct issuance method.

(5)Capital return

Regardless of whether it is a direct issue or an indirect issue,overseas borrowing with a term of more than one year requires prior filing by the National Development and Reform Commission(except for the pilot regions and pilot enterprises mentioned above).

In the case of direct issuance,in accordance with Article 2,Item 6 of the Notice,the raised funds will be used preferentially to support major project construction and investment in key fields such as the"the Belt and Road",the coordinated development of Beijing Tianjin Hebei,and the cooperation between the Yangtze River Economic Belt and international production capacity and equipment manufacturing.According to Article 10 of the"Notice of the People's Bank of China on Implementing Macro Prudential Management of Full Calibre Cross Border Financing Nationwide",enterprises shall,after signing the cross border financing contract but not later than three working days before the withdrawal,handle the signing and filing of the cross border financing situation with the capital account information system of the State Administration of Foreign Exchange.Otherwise,in accordance with Article 12 of the"Notice of the People's Bank of China on Implementing Macro Prudential Management of Full Calibre Cross-border Financing Nationwide",if it is found that cross-border financing information has not been submitted or changed in a timely manner,the People's Bank of China and the State Administration of Foreign Exchange will,after verification,circulate a notice of criticism to the financial institution or enterprise involved,Rectify within a specified time limit and investigate and deal with it in accordance with laws and regulations such as the Law of the People's Republic of China on the People's Bank of China and the Regulations of the People's Republic of China on Foreign Exchange Control.If it is found that cross-border financing is carried out beyond the upper limit,or the use of borrowed funds is inconsistent with the direction of national and free trade zone industrial macro control,the People's Bank of China and the State Administration of Foreign Exchange may order it to immediately correct,and may,based on the actual situation,impose penalties on the borrower in accordance with the relevant provisions of the Law of the People's Republic of China on the People's Bank of China and the Regulations of the People's Republic of China on Foreign Exchange Control;If the circumstances are serious,its cross-border financing business may be suspended.

If indirect issuance is adopted,in accordance with Article 2 of the"Notice of the State Administration of Foreign Exchange on Further Promoting the Reform and Perfection of Foreign Exchange Management and Real Compliance Review"(Hui Fa[2017]No.3),funds under domestic insurance and foreign loans are allowed to be repatriated for domestic use.The debtor can directly or indirectly transfer the funds under the guarantee back to China for use through loans,equity investment,etc.Therefore,since 2017,in indirect issuance,cross-border guarantee issuance provided by domestic parent companies has been widely used,and it is applicable to transfer the funds raised by overseas bonds back to China through domestic debt investment and equity investment by overseas issuers.However,within 10 working days after the successful issuance of US dollar bonds,it is sufficient to file with the local foreign exchange bureau where the domestic guarantor,i.e.the domestic parent company,is located.

Although the foreign exchange management department stipulates that the filing can be completed within 10 working days after the successful issuance of overseas bonds,in practical cases,the author has encountered difficulties in filing with the foreign exchange management department for some customers who have successfully issued overseas bonds through cross-border guarantees,which may lead to the inability to transfer domestic funds overseas to repay foreign debts after the maturity of overseas bonds.Therefore,the author suggests that:,Before issuing overseas bonds,the issuer should fully communicate with the local foreign exchange management department in advance to avoid future difficulties in the repayment of foreign debts due to the difficulty of funds exiting the country,leading to bond default.

(6)Issuance period

From the perspective of the issuance period of US dollar bonds,the issuance period from 2008 to 2012 is mainly dominated by those with a relatively high rating of over 5 years.From 2013 to 2015,the growth of 1-5 year bonds was relatively fast.From 2016 to 2017,the growth rate of 1-year or even less bonds was relatively fast.The issuance of US dollar bonds with a maturity of less than 365 days has increased from 1 in 2016 to 58 in 2017.The bonds issued in 2018 are mainly medium-and short-term bonds with a five-year maturity,accounting for over 87%.Among them,the issuance of 3-year and less bonds was$85 billion,an increase of$18.6 billion or 61.4%compared to the same period last year,an increase of 22.7 percentage points compared to the same period last year;The proportion of bonds with other maturities has decreased to a certain extent.In January 2019,of the 47 US dollar bonds that had been priced and issued,the proportion of bonds with a maturity of less than one year accounted for 12.2%.

The emergence of overseas bonds with a maturity of less than 1 year should be related to the provisions of the Notice.Domestic enterprises must obtain prior registration from the National Development and Reform Commission for overseas borrowing with a term of more than one year,while no registration requirements have been made for overseas borrowing with a term of less than one year.

3、Lawyer work for overseas bond issuance

As a domestic lawyer who undertakes overseas foreign debts,the author has conducted work exchanges with overseas lawyers during the practical work process,and found that there is a significant difference between the requirements for domestic lawyers in the issuance of overseas bonds and the issuance of bonds in China.

First of all,in terms of the division of duties of lawyers,when issuing bonds publicly overseas,there are mainly four law firms responsible for bond issuance,two domestic and two overseas,respectively serving as overseas lawyers for the issuer,domestic lawyers for the issuer,domestic lawyers for the underwriter,and overseas lawyers for the underwriter.If private placement is adopted,one domestic and one overseas law firm can be hired to provide services.

The full English version of the prospectus for overseas bond issuance is prepared by the overseas underwriter's lawyer,and the overseas lead underwriter is not responsible for this work.It is only responsible for coordinating the respective work of various intermediaries and issuers as a global coordinator,as well as the sales of bonds.The focus of domestic lawyer services is to review legal documents and prospectus,including the terms and conditions of bond issuance;Conduct due diligence on the issuer or domestic guarantor and its important subsidiaries,make judgments on the issues involved in the issuance in accordance with the laws and regulations in China,and issue a legal opinion in English to express clear legal opinions.The lawyer for the overseas underwriter shall prepare the content of the prospectus related to domestic laws and regulations based on the legal opinions of domestic lawyers.

Secondly,from the perspective of the submission time of Chinese legal opinions by domestic lawyers,when issuing bonds in China,a legal opinion must be submitted when the bond application materials are submitted to the regulatory authority.In the case of overseas US dollar bond issuance,according to the overseas bond issuance process,the legal opinion of domestic lawyers is to submit an English version of the legal opinion to the bond investor on the 7th working day after the bond is announced for trading,i.e.the bond delivery date.

Finally,when working with domestic lawyers,based on the characteristics of overseas investors in bonds,when issuing legal opinions,in addition to focusing on some key points of domestic bond issuance,it is also necessary to pay special attention to the following:

Judgment on the legality of the issuer or domestic guarantor and its important subsidiaries,as well as the legitimacy of the exercise of their legitimate rights.The limitation of important subsidiaries needs to be determined jointly by domestic and foreign law firms based on the specific situation of the issuer or domestic guarantor.It is not like conducting an investigation on all subsidiaries under the consolidated statements of the bond issuer when issuing domestic bonds,even if there are a large number of shell subsidiaries,Such subsidiaries lack substantial financial indicator contributions to the business of the issuer or domestic guarantor;

Analyze and judge the legality of the use of funds raised through overseas bond issuance,and determine whether the overseas bonds will be used in the use regions and projects described in the prospectus after issuance.If the use of funds involves internationally recognized sensitive and high-risk regions and projects,it should be treated with caution;

Whether the National Development and Reform Commission has filed in advance(except for overseas borrowing with a term of less than one year),and if the funds raised from bonds need to be transferred back to China for use,whether the due procedures of the foreign exchange management department have been followed;

Analysis and judgment of the legal situation of domestic environmental protection of the issuer or domestic guarantor and its important subsidiaries;Whether there are significant labor disputes involving human rights;Whether important assets have purchased relevant commercial insurance in China,and whether they comply with domestic commercial insurance policies;

Whether there are restrictive clauses for issuing bonds or providing external guarantees in the financing contracts of the issuer or domestic guarantor and its important subsidiaries,and if there are corresponding restrictive clauses,whether it is necessary to obtain the written consent of the lender,and whether it constitutes an analysis and judgment of cross breach in the financing contracts;

Analyze and judge whether the issuance prospectus of overseas bonds conflicts with domestic laws and regulations;

Whether relevant domestic regulations apply to the tax situation where the investment income(interest)obtained by the bondholder is income obtained overseas due to the issuance,delivery,and payment of overseas bonds outside China.If the issuer of overseas bonds is a special purpose company(SPV)established outside China,it will analyze the payment of corporate income tax by using equity investment or debt investment to return the raised funds to China for use.For bondholders,it is necessary to distinguish whether they are resident enterprises and determine whether they need to pay income tax,And whether the income obtained by bondholders after transferring bonds needs to be taxed in accordance with domestic regulations.

Analysis and judgment on the legal application of overseas bond issuance and whether domestic judicial assistance can be obtained in case of bond default.

4、Conclusion

In summary,the author believes that the requirements for domestic enterprises to issue bonds overseas are quite different from those for domestic enterprises,and the focus of lawyers'work is also different from that of domestic bonds.When conducting their work,domestic lawyers need to analyze the issuance factors such as the pre filing of the issuance,the issuing entity,the bond rating,the issuance period,the return of funds,and the issuance method,which can be reflected in the work of domestic lawyers,Reflect the key points of attention in the final legal opinion on overseas bond issuance,and promote the successful issuance of bonds by domestic enterprises overseas.

reference:

Wang Jingbo,Yu Hongchen,"Bond Game:Chinese Enterprises Engaging in the International Bond Market",published by Renmin University of China Press,August 2014.

Shi Yanping,International Financial Market,Renmin University of China Press,June 2010 edition

Zhang Tianshuo,Zhong Yanghui,"Insight into Overseas Bond Ratings","China Foreign Exchange",Issue 12,2017

Gu Xiaoye,"Discussion on Overseas Financing and Capital Return Modes of Chinese Enterprises","China Market",Issue 12,2017

Zhang Yumei,"Comparative Analysis of Overseas USD Bonds of China's Three Major Oil Companies","Contemporary Petroleum and Petrochemical",Issue 1,2014

(This article is translated by software translator for reference only.)