观点 | OPINION CHINA OFFSHORE
优惠政策或者税收优惠的情形将会减 少。因为此种情况下设立的开曼公司也 属于外国投资者，在国内投资 TMT 等行 业将受到严格限制。
exchange and many other barriers.
二、外国自然人或者外国法人通过在开 曼设立离岸公司，再通过其他配套架构 将资本投入国内企业的情况将会受到 限制，因为此种投资者投资国内的特定 行业（比如影响国家信息安全、影响国 内科技水平等）正是《外国投资法》要 严格规制的对象。
4. For start-ups with a VIE structure controlled by a domestic individual, this will affect their efforts to destroy their initial VIE structure. Although they can be directly identified as Chinese-invested enterprises, in the long run they will also lose opportunities to acquire capital injections by foreign VC investment agencies.
三、之前在开曼群岛注册公司并投资国 内被禁止或者限制的行业的外国投资 者们怎么办呢？没有办法，拆分既有的 VIE 架构返回境内上市或者转让股权给 具有合法受让资格的第三方将是必由
Besides all this, there is also a case that needs special attention. Chinese enterprises that are domestically invested would often, in order to strengthen control over the enterprises
or resolve the issue of inheritance of family wealth, establish trust by registering offshore companies in the Cayman Islands before enterprises were listed (if ever) to resolve marriage property planning, controlstrengthening over the enterprises, employee equity incentives, and family wealth inheritance. LongFor Estate achieved the aforementioned objectives by establishing complex structures in Cayman and elsewhere before listing, and Wu Yajun (owner of LongFor) and her husband Cai Yingkui divorced in a peaceful manner after the enterprise was listed because no split of the equity interest was required. Such a story wins praise from
Trusts & Foundations Guide CHINA OFFSHORE
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