Foreign-invested enterprises, with the same amount of "total investment" and "contribution" in the approval certificate, can still borrow foreign debts from the parent company?

I can't.

According to the Interim Measures for the Administration of Foreign Debt, the sum of the accumulated amount of medium and long-term foreign debt borrowed by foreign-invested enterprises and the balance of short-term foreign debt should be controlled within the difference between the total investment of the project approved by the examination and approval department and the registered capital.

Therefore, the foreign debt limit is generally called "gambling difference".

The amount of contribution in the approval certificate = registered capital. If the "total investment" and "contribution" are the same, the total investment is equal to the registered capital, that is, there is no "gambling difference" and foreign debts cannot be borrowed.

The solution is to submit an application to the original examination and approval authority to modify the total investment.