A common 2026 treasury setup: HK entity for mainland-adjacent trade settlement and RMB flows; Singapore for USD/EUR treasury, regional HQ functions, and geopolitical-hedging banking diversification — with intercompany loans documented on both sides.
Playbook: (1) HK entity — procurement/sales settlement, RMB cross-border pooling (Cash Management), close coordination with mainland operations; cost-efficient. (2) Singapore entity — regional treasury, USD funding, VC-facing holding, banking diversification amid geopolitical hedging; requires more substance (EP director or real staff). (3) Intercompany framework: loan agreements with arm's-length rates (reference: OECD/Chinese safe-harbour ranges), service agreements with markup, and TP documentation in each jurisdiction. (4) Cash pooling: notional pooling availability varies by bank; physical sweeping needs loan documentation. (5) China forex controls: cross-border pooling requires SAFE registration; keep ODI chain clean. (6) Sequence for founders: usually HK first (speed), Singapore when treasury scale or investor geography justifies it.
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