Submission in response to Foreign Investment Framework Reforms – Discussion Paper, 31 Oct 2025

I argue that Treasury should prioritise targeted reform of the “associates or influence” capture rules for sensitive activities , particularly processing and refining of critical minerals, rare-earths value chains and dual-use technologies. The reform should be combined with streamlined guarantees for objectively low-risk investments. The recent assumption of operational control over Nexperia (a major semiconductor firm owned by the Chinese corporation Wingtech, which is listed on the United States Department of Commerce’s Entity List for technology export control purposes) by the Government of the Netherlands underscores the strategic implications of indirect ownership and influence in sensitive sectors. Nexperia’s example also illustrates how opaque corporate structures can mask strategic influence and why reform in this area is now urgent