The classification screen

4 questions before you choose the route.

This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.

01

What does the bank file show?

SWIFT, capital-account, RMB receipt.

Bank
02

Any in-kind actually transferred?

Title vs promise.

In-kind
03

Does SAMR disclosure match?

Annual report / publicity system.

Public
04

Gap vs subscribed?

Five-year clock.

Gap

Working rule: Paid-in (paid-in contribution) capital is the amount actually contributed. For FIEs it usually shows up through the capital account and bank receipts; in-kind needs valuation and transfer of title.

What changes the answer

The signal ledger.

These facts move the question beyond a label and into a product, money-flow and control analysis.

Signal
Ask the operating question
Why it changes the route
Licence as proof of cash
Showing only registered capital.
Wrong number.
Round-trip funds
Same-day in and out.
Not a real contribution.
Skip FX page
Onshore story without SAFE.
Incomplete.
Prepare before you escalate

Bring a compact evidence docket—not a pitch deck.

Give a compliance team or counsel the operating facts that reveal the perimeter.

01Bank receiptsCapital account.
02Valuation and title docsIn-kind.
03Shareholder ledgerWho has paid.
Common confusions

Questions people ask before they build.

Short answers for orientation. The right result can change with the service model and current rules.

Do we still need a CPA verification report?

Not as a universal Company Law step. Banks and some licences still ask. Confirm the counterparty.

Can we count a shareholder loan as paid-in?

Generally no. Loan is debt; capital is equity.

Primary authorities

Reviewed sources support orientation, not a fact-specific assessment.

PRC Company Law (NPC laws database)
SAMR
Gov.cn
National laws database (NPC)