Ref: FSD-2025-003 Verified: July 15, 2026

Financial Strategic Directive: Leveraging Sino-Slovenian Tax Treaty and Offshore Yuan Liberalization

Executive Liquidity Summary "This directive provides a comprehensive strategy for utilizing the new offshore yuan direct transaction channels and the favorable tax treaty between China and Slovenia. Key actions include restructuring cross-border investments to benefit from reduced tax rates, establishing yuan-denominated financing and treasury operations, and expanding into Central and Eastern European markets via Slovenia as a gateway. The directive emphasizes compliance, risk management, and operational adjustments to maximize returns while mitigating tax and regulatory risks."
China's policy allowing six banks to conduct offshore yuan transactions directly from the mainland, combined with the Sino-Slovenian tax treaty offering reduced withholding tax rates on dividends (5%), interest (5%), and royalties (10%), with potential 0% rate under certain shareholding conditions, presents a unique opportunity for multinational corporations and financial institutions to optimize cross-border investment structures. This directive outlines strategic actions to capitalize on these developments, enhancing capital efficiency and tax optimization.
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