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三家部委表面上是均对境外投资负责,各司其职,但审批内容重叠,职能交叉,权力的转移并未使前置审批程序与内容发生实质性改变。这与加入WTO后减少行政审批,并对行政审批制度进行改革的精神不符。各部门、各级别的层层审批加大了项目的成本,有时企业在一个项目所能得到的政策优惠,可能刚刚抵偿层层审批所花的费用。政府各部门审批项目的行政成本和企业的交易成本均未减少,这反映出对外投资审批制度的内在缺陷以及改革的迫切性。审批权的横向转移并未从根本上解决简化审批的问题,有时甚至使问题更加复杂化。
On the surface, all three ministries are responsible for overseas investment and have their own duties. However, the contents of examination and approval overlap, functions are crossed, and the transfer of power does not make substantive changes to the pre-approval process and content. This is incompatible with the spirit of reducing administrative examination and approval after China’s accession to the WTO and reforming the administrative examination and approval system. All departments and levels at different levels of examination and approval increased the cost of the project, and sometimes enterprises can get preferential policies in a project, may have just offset the costs of approving layers. The administrative costs of approving projects by various government departments and the transaction costs of enterprises have not decreased, reflecting the inherent defects of the examination and approval system for overseas investment and the urgency of reform. The horizontal transfer of the power of examination and approval has not fundamentally solved the problem of simplifying examination and approval, sometimes even complicating the issue.