China

PwC China

26/F Office Tower A, Beijing Fortune Plaza

7 Dongsanhuan Zhong Road, Chaoyang District

Beijing 100020

PRC

Tel: +86 (10) 6533 3018

Fax: +86 (10) 6533 8800

Email: xiaoying.chen@cn.pwc.com

Website: pwc.com/taxcontroversy

Xiaoying Chen is the north region tax controversy services (TCS) lead partner, based in the Beijing branch of PwC China. She holds the qualification as a registered tax agent of PRC. Xiaoying has been committed to providing tax controversy services on M&A, corporate restructuring and other complicated tax issues since her joining PwC in 2001. She leads a strong TCS team, which is composed of experienced ex-Chinese tax officials and senior tax managers.

Before joining PwC, Xiaoying served at the State Administrating of Taxation (SAT) for 16 years. She works in several departments of the SAT, including the general office and the goods and services tax departments, among other roles. She has deep intelligence regarding China tax and historical development, and is very knowledgeable about the China tax collection and administration system. She is familiar with the methods and procedures of the tax audit administration in China.

In PwC, Xiaoying is also actively involved with the Ministry of Finance (MOF) and the SAT for research and advisory projects regarding the tax legislation. For example, she providing valuable comments to the MOF and SAT's joint circulars, Caishui [2009] No.59, and Guoshuihan [2009] No.698. She pushed forward the issuance of the MOF and SAT's joint circular, Caishui [2012]No.48 and Shuizonghan [2013] No.165.

Xiaoying is a top tax expert, even within PwC, having the relevant working experience from the perspective of both the SAT and the international accounting firms. She is especially skilled in consulting and coordinating disputes between tax authorities and taxpayers, as well as resolving M&A and capital markets related taxes issues. Xiaoying provides insightful advice to clients on the interpretation of tax laws and regulations, coordinates the resolution of tax controversy, and assists clients to properly protect their lawful rights and interests. With Xiaoping's help, one of her clients became the first taxpayer in China to obtain the confirmation of special corporate income tax treatment for its corporate restructuring. She also assisted various foreign tax residents in communicating with the central and local level tax authorities for indirect transferring of PRC target companies. Many state-owned enterprises and domestic private enterprises engage her as their retaining tax adviser.

Xiaoying's clients' industries cover financial services, insurance, TMT, real estate, healthcare, consumer goods, logistics, manufacturing, and agriculture, among others.

PwC China

10th Floor, Shui On Plaza

333 Huai Hai Zhong Road

Shanghai 200021

PRC

Tel: +86 (21) 2323 2580

Fax: +86 (21) 2323 8800

Email: spencer.chong@cn.pwc.com

Website: pwc.com/taxcontroversy

Spencer Chong is a tax partner of PwC China and is the tax markets leader of PwC Hong Kong & China. Spencer is also the founder and leader of the Transfer Pricing Services practice for Greater China. Under Spencer's leadership, PwC China/Hong Kong was awarded the China Transfer Pricing Firm of the Year award in 2006 and Hong Kong Transfer Pricing Firm of the Year in 2009 by the International Tax Review. Before joining the firm, Spencer worked at the Hong Kong Inland Revenue Department. He has more than 25 years of experience in tax and transfer pricing consulting.

Spencer has been involved in numerous tax and transfer pricing projects. He is experienced in assisting investors in formulating structuring defence and negotiation strategies and fronting such negotiations in difficult tax audit defence cases. He provides value-added advice in global/regional structuring studies aimed at achieving companies' business and profit alignment goals.

Spencer is a regular speaker on Chinese tax and transfer pricing issues and trends for professional conferences and contributes frequently to professional publications on the subject.

Spencer manages the firm's 'High potential cities' initiative, as well as managing the legal practice. On top of his involvement in securing the first five advance pricing agreements (APAs) negotiated in China, Spencer assisted a prominent Korean multinational group in securing the first bilateral APA between Korea and China, assisted a Danish multinational group in securing the first bilateral APA between China and Europe, and was also involved in the first bilateral APA between China and Singapore.

PwC Hong Kong

Email: frank.l.feng@hk.pwc.com

Website: pwc.com/taxcontroversy

Frank L Feng is a senior tax policy adviser of PwC Hong Kong.

Before joining PwC, Frank had been working in the State Administration of Taxation (SAT) for more than 17 years. His final position in the SAT was director of the Tax Treaty Division within the International Taxation Department. For more than 12 years, he had been engaged in bilateral tax treaty negotiations, drafting circulars to interpret tax treaty provisions for the purpose of application, handling cases of treaty application or double taxation through the mutual agreement procedure (MAP), and regularly participating in the OECD meetings of Working Party 1 on tax conventions and related issues. Frank is very knowledgeable with international taxation policies and administration.

Being the original author of the Chinese MAP application, acceptance and examination procedures, Frank has deep insights on how to solve cross-border tax controversies through MAP. Frank had first-hand experience in handling and settling MAP cases, which were not commonly used until recently, as more and more cross-border tax disputes of significant tax amounts involved arise. Through his previous exposures, he established and is maintaining a good network with the competent authority officials of other jurisdictions, which puts him in an advantageous position in dealing with MAP cases.

In his capacity as senior tax policy adviser of PwC Hong Kong, Frank has contributed a lot in providing advice on the evolving international and Chinese tax policies and interpretation on permanent establishment constitution, attribution of profits, royalties, capital gains, international traffic, non-discrimination, dual residency, beneficial ownership, general anti-avoidance rules, and more. He is also the 'go-to–person' as far as MAP is concerned.

PwC China

10th Floor, Shui On Plaza

333 Huai Hai Zhong Road

Shanghai 200021

PRC

Tel: +86 (21) 2323 3824

Fax: +86 (21) 2323 8800

Email: liang.gong@cn.pwc.com

Website: pwc.com/taxcontroversy

Liang Gong is a tax partner in PwC China's Shanghai office. He has more than nine years' experience in providing China tax and business advisory services for multinational companies and China domestic companies.

Before joining PwC, Liang had seven years of working experience in Qingdao State Tax Bureau and gained first-hand experience in value added tax (VAT) refund, tax audit and tax administration issues. During that time, Liang was often called up by the State Administration of Taxation to join the taskforce of many nationwide tax audits. Further, Liang shared his experience and viewpoints via articles in several national and provincial journals.

Liang has been dedicated to providing China tax and business advisory services for his clients, and he is experienced in tax controversy and China indirect tax services. His major industrial focus areas include manufacturing, FMCG, and real estate, among others. Over the years, Liang has achieved various successful outcomes for his clients on tax controversy cases in a wide range of VAT, business tax, export VAT refund, withholding tax on passive incomes, permanent establishment, and other tax audit defence cases.

Liang's capacity covers China tax and structure advisory services, tax negotiation, China indirect tax, tax internal control, foreign contractor advice, tax due diligence and health checks, tax audit/investigation support, cash management, and so on.

Liang has an MBA from the University of Oxford as well as a master's degree in economics from Renmin University. Liang obtained his bachelor of economics with a major in taxation from Xiamen University. He also holds his CTA qualification.

Deloitte China

8/F Office Tower W2

The Towers, Oriental Plaza

1 East Chang An Avenue

Beijing, 100738

China

Tel: +86 10 85207666

Email: lhe@deloitte.com.cn

Lian-Tang is the co-leader of the Deloitte China transfer pricing team and a core tax controversy team member.

Lian-Tang worked with the State Administration of Taxation for more than 28 years and served as chief of the Anti-tax Avoidance Division, International Tax Section, as well as chief of the Third Office of Large Enterprise Taxation, Administration Section (Management of Tax Risks of Large Enterprises). He was the main architect of Chinese transfer pricing regulations. He has practised in taxation relative to the oil and gas industry since 1984, and is an international tax and tax management specialist in this area.

Lian-Tang has substantial experience serving multinational clients in negotiation of APAs and other rulings, formulation of internal transfer pricing policy, audit defense and tax planning.

Deloitte China

30/F Bund Center

222 Yan An Road East

Shanghai, 200002

China

Tel: +86 21 6141 1465

Fax: +86 21 6335 0003

Email jnjiang@deloitte.com.cn

Mike Jiang is a Deloitte China tax partner based in Shanghai.

Between 1997 and 2008, Mike was with the Foreign Taxation Branch of Shanghai State Tax Bureau and gleaned a broad range of first-hand experiences through a profound portfolio of cases. Mike has held positions in various departments of the branch, including the tax policy, tax administration, and tax audit departments. During this period, his responsibilities included taxation management, tax inspection and explanation of tax policies regarding foreign invested enterprises. Mike's proven record with the tax authorities has further been endorsed by his five-year plus leadership role during his 11-year tenure with the bureau.

Since joining Deloitte China, Mike has been dedicated to providing China tax and business advisory services to his clients, particularly in rendering tax controversy services given his seasoned background. His major industrial focus includes manufacturing and real estate.

Over the years, Mike has achieved various successful outcomes for his clients in tax controversy cases involving a wide range of issues, such as: tax audit support, enterprise income tax (EIT), overseas remittance, permanent establishment, beneficial ownership, VAT exemption, and many more.

Since 2002, Mike has become a frequent and sought-after speaker at various tax policy seminars hosted by renowned organisers, such as the Shanghai Institute of Certified Accountants, Shanghai Foreign Invested Enterprises Committee and many accounting firms. Meanwhile, Mike has also published articles in various magazines such as Shanghai Finance and Taxation, and contributed to tax policy research in Shanghai along the way.

Mike is a certified public accountant (CPA) and a certified tax agent (CTA) in China.

PricewaterhouseCoopers Guangzhou Office

18/F, PwC Center, 10 Zhujiang Xi Road

Pearl River New City, Tianhe District

Guangzhou, 510623

PRC

Tel: +86 (20) 3819 2189

Fax: +86 (20) 3819 2100

Email: daisy.kang@cn.pwc.com

Website: pwc.com/taxcontroversy

Daisy is a tax director of PricewaterhouseCoopers Guangzhou office. She is specialised in providing solutions to clients' tax controversy issues, including tax investigations, tax disputes, tax rulings, and applications for favourable tax treatments, among others.

Before joining PricewaterhouseCoopers, she was a tax official of the Tax Assessment Branch of the Xiamen State Tax Bureau. Daisy spent more than 10 years at the Xiamen State Tax Bureau, where she was mainly responsible for multinational companies' tax assessment matters. Plus, she was also extensively involved in reviewing tax audit cases when she was a Xiamen State Tax Bureau, where she provided technical support to the investigation teams.

Daisy's portfolio includes giant multinational groups and big name SOE clients engaging in the industries of energy and utilities, manufacturing, media, automobile, logistics, real estate and fast consumption products. She helped these clients in formulating strategies to defend their tax position which cover a wide spectrum, taking into account income tax, withholding tax, value added tax, business tax, real estate tax and transfer pricing matters. She also helped clients to obtain favourable advance tax rulings from tax authorities, including tax preferential treatments for the envisaged restructuring.

During her time at the PricewaterhouseCoopers Guangzhou office, Daisy participated in various technical training and workshops conducted by the tax bureaus across China and maintaining close contact with the tax officials in major cities in Southern China. Daisy also established good relationships with the other authorities at the state level, including the State Administration for Taxation and the Ministry of Commerce.

Deloitte China

Unit 7, 20F Bund Center

222 Yan An Road East

Shanghai

China

Tel: +86 21 6141 1308

Fax: +86 21 6141 0003

Email: eunicekuo@deloitte.com.cn

Eunice Kuo, a tax partner of Deloitte China, is the national leader for China/Hong Kong cross-border tax services, in charge of transfer pricing, business model optimisation (BMO) and tax structuring services.

She has 28 years of experience providing cross-border tax services. Before joining Deloitte China in 2010, she was the tax practice leader and led the transfer pricing and international tax teams of Deloitte Taiwan.

Eunice has many years' experience providing transfer pricing services. She started Deloitte Taiwan's transfer pricing practice, where she has helped clients by preparing transfer pricing reports, planning for cross-border transactions including those involving supply chain issues, performing transfer pricing due diligence for M&A projects, helping to mitigate transfer pricing risk, assisting in settling tax audit cases, helping with the conclusion of advance pricing agreements (APAs) and mutual agreement procedures (MAPs), and advising on tax issues arising from business restructures. Eunice has led MAP and APA projects as well as significant tax dispute cases, and has successfully helped clients achieve satisfactory results.

Eunice is experienced in solving complex and difficult tax dispute cases for clients. She has helped clients through formal tax controversy processes and has also helped clients close tax disputes through negotiation and settlement.

Eunice is a Taiwanese certified public accountant (CPA) as well as a Chinese CPA. She has been named a leading transfer pricing adviser consecutively every year by Euromoney. She was also named one of the 'Best of the Best' in global transfer pricing by International Tax Review in 2013-2014.

Eunice is a frequent speaker at public seminars and trainings for the tax authorities. She has been active in associations in Shanghai and has spoken on behalf of enterprises. Eunice has also contributed articles on transfer pricing to International Tax Review and other publications.

Deloitte China

Unit 7, 20/F Bund Center

222 Yan An Road East

Shanghai 200002

PRC

Tel: +86 2161411048

Email: mlin@deloitte.com.cn

Martin Lin leads the Deloitte China tax controversy service which consists of more than 30 controversy specialists, former tax officers and lawyers. Martin has extensive experience in international taxation and tax risk management, and has worked closely with central and local tax authorities on policy making and dispute resolution. The tax controversy team of Deloitte China has substantial experience dealing with defence of anti-avoidance inspections and negotiations, regular tax audits, administrative reviews, applications for rulings and other tax administrative confirmations.

Martin has worked with Deloitte Tax LLP (Deloitte US) and the Deloitte China tax practice for the past 25 years.

PwC

26/F Office Tower A, Beijing Fortune Plaza

7 Dongsanhuan Zhong Road, Chaoyang District

Beijing 100020

PRC

Tel: +86 (10) 6533 3103

Fax: +86 (10) 6533 8800

Email: long.ma@cn.pwc.com

Website: pwc.com/taxcontroversy

Ma Long is a tax partner within the tax controversy services (TCS) practice based in Beijing, China.

Ma has 15 years of experience in providing Chinese tax and business advisory service to multinationals and Chinese enterprises. His extensive experience from a variety of assignments has covered a broad spectrum of industries and client types. He started his professional tax career in 2000 and worked in PwC's New York office on a secondment during 2006/2008 before being admitted as partner to the Beijing Office of PwC China in July 2014.

Ma has a close working relationship with key departments of the Chinese State Administration of Taxation (SAT). His familiarity with SAT officials and in-charge officers at various provincial and municipal tax offices is effectively functioning as a communication channel between tax bureau and taxpayers. He has assisted in resolving tough tax controversy issues and represented clients in tax negotiations in different locations in China. His leverage of the connections and resources he has within the Chinese tax system is highly valued and appreciated by clients.

In recent years, Ma has extensively provided tax service in various fields, including application for tax treaty treatment, mutual agreement procedure (MAP) involving both SAT and local level tax authorities, defence against the application of GAAR on cross-border transactions. He has been engaged in various cases on tax audit defence, and his proven track records of success in defence has been well recognised by his clients. The experiences gained in these pursuits have proved a valuable resource for the TCS team.

Ma graduated from the law school of Peking University with a double bachelor degree in law and economics. He is a China certified tax agent.

PwC China

26/F Office Tower A, Beijing Fortune Plaza

7 Dongsanhuan Zhong Road, Chaoyang District

Beijing 100020

PRC

Tel: +86 (10) 6533 3028

Fax: +86 (10) 6533 8800

Email : matthew.mui@cn.pwc.com

Website: pwc.com/taxcontroversy

Matthew Mui is national leader of national tax policy services and tax controversy services for PwC China.

Matthew has nearly 30 years' experience in providing China tax and business advisory services to multinationals, Chinese domestic and Hong Kong enterprises covering a wide range of industries. He started his professional tax career in Hong Kong and in July 2000 he was admitted as partner to the Beijing office of PwC China.

In his capacity as national tax policy services partner, he supports the practice nationally in respect of capturing the latest tax and business regulatory developments, exploring tax efficiency opportunities for clients and sharing professional experience with the practice members.

He has very closed working relationship with all of the key departments of the Chinese State Administration of Taxation (SAT). He is often invited to advise on the formation of state tax policies.

Because of this familiarity with the key tax policymakers and the processes behind Chinese tax policy-making, Matthew has the advantage of appreciating the motivations behind tax policies and the approach of implementing the tax policies, and is in a strong position to communicate taxpayer views to the SAT. Thus, Matthew's unique calibre has proved to be very helpful in preventing, managing, and resolving tax controversies between taxpayers and tax authorities in China.

Matthew is fluent in Putonghua, English and Cantonese. He is a fellow member of the Association of Chartered Certified Accountants and the Hong Kong Institute of Certified Public Accountants. He is often recognised as a top adviser for China tax controversies, including in International Tax Review's Tax Controversy Leaders guide.

Deloitte China

30/F, The Exchange North Tower No.1

189 Nanjing Road

Heping District

Tianjin 300051

PRC

Tel: +86 22 2320 6680Emailjassu@deloitte.com.cn

Jason Su has gained 28 years of solid experience in providing multinational and local clients in Tianjin with China tax and business consulting services, which mainly includes tax planning, corporate restructuring and advice on business and tax issues related to day-to-day operations of foreign investment enterprises of various industries. Jason is a Tianjin Economic-Technological Development Area (TEDA) business consultant, lead partner of the YuJiaPu Financial District overall strategic service project, financial risk management and control programme partner of Tianjin Port Free Trade Zone Committee, and lead partner of Airbus negotiation, among other roles.

Before joining Deloitte China, Jason served the various tax bureaus in Tianjin for more than 12 years. His solid Chinese tax knowledge and experience enables him to provide quality and practical advice. He actively represents clients in discussions with tax authorities in connection with tax disputes and obtaining preference incentives.

Deloitte China

30/F, The Exchange North Tower 1

189 Nanjing Road

Heping District

Tianjin 300051

PRC

Tel: +86 22 23206609

Email: ftang@deloitte.com.cn

Frank Tang is a tax partner with Deloitte China, who has dedicated more than 26 years of his professional career to China tax development and practice.

His career started in 1987, when he joined the foreign taxation branch of Tianjin Municipal State Tax Bureau of China as a tax officer. He is one of the first tax officers in China who has dealt with international taxation after the policy of reform and opening-up has been widely rolled out in China. Frank handled various important international and domestic tax cases back then and his work has earned him wide recognition from the taxpayers, the tax authority, as well as the tax professionals.

Frank joined Deloitte China in 2001. During the past 14 years, he has provided excellent services to a great number of multinational and domestic clients in helping them to properly manage their tax matters. He has extensive experience in various tax and business related areas including tax controversy, customs disputes, advance pricing agreements (APAs) and transfer pricing audit defence, China tax planning, compliance and business advisory. In the meantime, Frank has also maintained a very good working relationship with multiple levels of PRC government authorities, including tax authority, customs office, Administration of Foreign Exchange, Investment Promotion Bureau, and others. He is also well respected by the government authorities.

The proven track records of his practice as well as his solid technical skills have made Frank highly regarded by his clients. He now represents significant number of enterprises from multinational companies to small business in the fields of manufacturing, servicing, banking, and construction and engineering.

In 2013 and 2014, Frank was recognised in Tax Controversy Leaders guide, published by ITR, which bases its research on a wide range of interviews with clients and other professional lawyers and advisers.

PwC China

10th Floor, Shui On Plaza,

333 Huai Hai Zhong Road

Shanghai 200021

PRC

Tel: +86 (21) 2323 2896

Fax:+86 (21) 2323 8800

Email: Jane.y.wang@cn.pwc.com

Website: pwc.com/taxcontroversy

Jane is a tax partner with the Shanghai practice of PricewaterhouseCoopers China. She has more than 18 years of specialist tax experience in China providing tax advice to both multinational companies and domestic companies.

During her professional years, Jane has developed extensive experience in providing tax and business consultation to many major US and European multinational clients investing in China. Jane has also participated in serving a wide spectrum of domestic clients. The services include tax and operational compliance review, tax investigation support, negotiations and advisory services in relation to tax audit defense, corporate restructuring on holding and trading structure, mergers and acquisitions support etc.

By effectively and efficiently dealing with relevant authorities and closely working with her clients, Jane has gained significant experience successfully minimising her clients' tax exposure and eliminating the overall tax cost. She has achieved successful outcomes for her clients on negotiation cases including indirect share transfer, withholding tax on passive incomes, permanent establishment, and other tax audit defence cases.

In Jane's 18 years working in China, she has developed extensive network with various tax authorities (for example, SAT, state and local tax bureaus in different regions, among others) as well as other government authorities. Jane has been frequently invited by the tax authorities to provide them the tax technical training courses.

PwC Guangzhou

18/F, PwC Center, 10 Zhujiang Xi Road

Pearl River New City, Tianhe District

Guangzhou, 510623

PRC

Tel: +86 (20) 3819 2193

Fax: +86 (20) 3819 2100

Email: janet.xu@cn.pwc.com

Website: pwc.com/taxcontroversy

Janet is a tax partner at PwC Guangzhou, China. She has more than 20 years of tax professional experience, of which 17 years have been in Chinese tax practice.

Janet has substantial experience in advising companies on dealing with tax audit, managing tax disputes on Chinese tax controversy issues, as well as proactively managing tax risks via application for tax rulings, among other areas.

Janet also has extensive experience in providing PRC tax consulting on indirect tax, M&A, and corporate reorganisation and restructuring related to PRC tax issues. She has been serving companies across a broad range of industries, including consumer and industrial manufacturing, retail, trading, banking and financial services.

Janet has developed extensive networks with various government departments, such as state and local tax bureaus and local bureaus of foreign trade and economic cooperation, of the Guangdong region through her China tax career.

Janet received her tertiary education in Australia where she received both her bachelor's degree in international business and her master's degree in accounting. She is a member of the Institute of Chartered Accountants in Australia.

Deloitte China

8/F Office Tower W2, The Towers, Oriental Plaza

1 East Chang An Avenue

Beijing 100738

PRC

Tel: +86 10 85207511

Email: juliezhang@deloitte.com.cn

Julie Zhang is a Deloitte China tax partner based in Beijing, specializing in international tax, mergers and acquisitions. She has 14 years of experience advising financial investors and multinational corporations in various industries on the PRC and international tax implications of a wide range of issues related to investment in China, including entry strategies, joint venture formation, mergers and acquisitions tax planning, reorganisations, post-merger integration strategies, permanent establishment issues, application of tax incentives, among others.

Julie received her JD with distinction from Stanford Law School and bachelor of arts from the Foreign Affairs College in China. She is licensed to practise law in the states of New York and California. In recent years, Julie has been recognised by prestigious publications including International Tax Review, Chambers Asia Pacific and Legal 500 Asia Pacific.

Deloitte China

8/F Office Tower W2

The Towers, Oriental Plaza

1 East Chang An Avenue

Beijing, 100738

China

Tel: +86 10 8520 7508

Fax: +86 10 8518 1326

Email: andzhu@deloitte.com.cn

Andrew Zhu is the partner-in-charge of the Deloitte Northern China strategic client tax services group and a member of the tax controversy group. He has more than 24 years of experience in Deloitte China and Deloitte Tax LLP (Deloitte US) tax practices, and extensive experience in global tax planning, compliance and structuring. He represents large multinational clients in dealing with tax disputes with the Chinese revenue agencies and customs administration. He also advises Chinese based companies on handling various tax audits.

Before joining Deloitte China, Andrew had seven years of experience working for the Chinese State Administration of Taxation (national office). During his tenure with the Chinese tax authority, he undertook senior responsibilities including drafting two of 18 current Chinese tax laws and other policies, and served as one of the key representatives from the Chinese tax authorities responsible for the tax issues on foreign investment in China. Andrew now serves as a specially invited tax expert by the National People's Congress, Ministry of Finance and the SAT assisting in the China taxation reform.

Andrew is a CPA both in China and in the United States. He is a frequent speaker regarding Chinese business and tax issues at various conferences and has published more than 40 articles and (co-authored) three books on Chinese taxation both in English and Chinese.