Leading FSR Compliance Fan Zhang Among First to Submit Feedback on EU Foreign Subsidies Guidelines
On March 5, 2025, the European Commission officially opened public consultations on the draft Guidelines under the Foreign Subsidies Regulation (FSR) (Regulation (EU) 2022/2560), aiming to clarify the implementation of disclosure and review mechanisms for foreign financial contributions (FFCs) affecting the EU internal market.
Lawyer Fan Zhang, Director of the Foreign Legal Affairs Department at JINGSH Chengdu, was one of the earliest legal professionals worldwide to submit feedback through the EU Better Regulation platform.
Her comments addressed complex issues surrounding the classification of tax exemptions, subsidies, and financial contributions under the FSR framework.
Key Issues Identified by Lawyer Fan Zhang
In her feedback, Fan Zhang raised critical legal interpretation questions, including:
- How to distinguish between “tax holidays”and “measures of general application” under FSR disclosure rules;
- Whether UAE corporate tax thresholdsand 0% tax for Qualifying Free Zone Persons constitute notifiable financial contributions;
- How Chinese corporate tax exemptionsand FDI incentives should be treated under the FSR framework—whether they are “general” or “limited” in application;
- Broader concerns over potential regulatory imbalancesthat might favor domestic-oriented businesses over internationally active exporters.
Her early input reflects both technical depth and strategic foresight, positioning her as a leading expert in navigating the complexities of FSR compliance for multinational clients.
Launching Comprehensive FSR Legal Advisory Services
With early, deep involvement in the FSR’s evolving interpretation, Lawyer Fan Zhang and JINGSH Chengdu have launched a comprehensive suite of FSR Advisory and Filing Services, including:
- Subsidy Assessment
- Form Preparation (Form-PP and Form-CO)
- Regulatory Risk Analysis
- Engagement with EU Authorities
Fan Zhang’s international legal expertise—covering jurisdictions including the UAE, China, South Korea and Europe—ensures clients receive globally integrated, EU-compliant FSR solutions.
Continuing Leadership in Global Regulatory Trends
Building on her early engagement with the FSR consultation, Lawyer Fan Zhang continues to monitor regulatory developments closely, offering informed perspectives on international compliance issues.
Her work strengthens JINGSH Chengdu’s positioning in supporting enterprises involved in cross-border transactions, investments, and competition-sensitive activities within the European market.
“Early dialogue with regulators is essential to shaping effective compliance strategies,” said Lawyer Fan Zhang.
“We remain committed to helping clients navigate global regulatory challenges with precision and foresight.”
As regulatory frameworks such as the FSR evolve, proactive legal insight remains critical for businesses seeking to maintain competitiveness and regulatory certainty in international markets.
