Bill Bai, Deloitte China, has more than 14 years of professional experience in China tax, where he has grasped abundant government working experience. He specialised in transfer pricing audits for about eight years and has already accumulated considerable transfer pricing experience both in theory and practice.
26/F Office Tower ABeijing Fortune Plaza
Xiaoying Chen is the north regional leader of tax controversy services (TCS) at the Beijing office of PwC China. She is a certified tax agent of the PRC. She has been providing tax controversy services related to complicated tax disputes since joining PwC China in 2001. She leads a TCS team comprising many experienced former tax officials and senior tax managers.
Before joining PwC China, Xiaoying worked in the State Administration of Taxation (SAT) for 16 years since 1985. During this period, she participated in the research, drafting and amendments of a series of important tax legislation proposals, and accumulated tremendous experience in tax collection management. She is an expert in the legislative thinking, detailed regulations and historical development of China's tax laws and regulations and is familiar with tax administration, tax audit's methodology and procedures.
Since joining PwC China, Xiaoying has actively continued her research and advisory role on tax laws and regulations with the Ministry of Finance (MoF) and the SAT. She provides important advice to the MoF and the SAT on some vital tax regulations on M&A, and proactively drives the issuance of some regulations relating to international taxation.
Xiaoying is one of the few top level tax experts, even in PwC China, with the experience of both the SAT and top-level international accounting firms. She accumulated extensive experience in M&A tax disputes and the related implementation. She assisted a client in getting the first special tax treatment in a M&A deal in China, and assisted various foreign institutions/funds in negotiating various tax related matters with all levels of tax authorities for exit deals from China. Xiaoying also assisted the first REITs issued in China to negotiate its tax treatments with all levels of tax authorities, and set an excellent example for all later REITs' tax-related structures issued in China. In addition, Xiaoying acted as a tax adviser for Beijing-Zhangjiakou, applying for the 2022 Winter Olympic Games. She assisted the related taxpayers to solve tax issues related to the transformation from business tax to value-added tax (B2V), and related disputes upon China implementing the B2V reform nationwide. She is the tax adviser of many state-owned enterprises and domestic private enterprises. She helped a lot of famous domestic private enterprises in getting listed in overseas capital markets, offshore M&A, and privatisation delisting.
5/F, 3 Corporate Avenue
Spencer Chong is a tax partner of PwC China and is the tax markets leader of PwC Hong Kong and 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 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 South Korean multinational group in securing the first bilateral APA between South 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.
26/F Office Tower A
Frank Feng is a tax director of PwC China, Beijing Office.
Before joining PwC China, Frank worked 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 was 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 has first-hand experiences in handling and settling MAP cases, which were not commonly used until recently, as more and more cross-border tax disputes have arisen, involving significant tax amounts. Through his prior 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.
Frank has handled or helped to handle cases in relation to permanent establishment constitution, attribution of profits, royalties, capital gains, international traffic, non-discrimination, dual residency, beneficial ownership, general anti-avoidance rules, among others.
5/F, 3 Corporate Avenue168 Hu Bin RoadHuangpu District
Liang Gong is a tax controversy partner in PwC China, Shanghai office, and leads the tax controversy practice in the central region of PwC China. He has over nine years' experience in providing China tax and business advisory services for multinational enterprises and domestic companies.
Before joining PwC China, Liang had seven years of working experience in Qingdao State Tax Bureau and gained first-hand experience in VAT refund, tax audit and tax administration issues. During that time, Liang was often called up by the State Administration of Taxation (SAT) 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 services. His major industrial focuses 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 corporate restructuring, VAT, business tax, export VAT refund, treaty benefits, tax audit defence and tax appeal cases.
Liang's capacity covers China tax and structure planning, tax negotiation, China indirect tax, tax internal control, foreign contractor advice, tax audit/ investigation support, as well as others.
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's degree in economics with a major in taxation from Xiamen University. He also holds a CTA qualification.
|Cathy Kai Jiang|
Tel: +852 2289 5659
Cathy Kai Jiang is a tax and china business advisory service partner and a China tax expert specialising in M&A due diligence review, deal negotiation support, tax restructuring, and post-deal integration. She is also PwC's partner-in-charge of the southern China domestic market initiative (DMI).
Cathy lends her talents to both multinational and domestic enterprises across many industries. She is on the frontline of the practice as leader of the southern China DMI, as she has been extensively involved in large numbers of A-share, overseas initial public offering projects, as well as China domestic outbound investment plans for China-based enterprises.
As a member of the Institute of Certified Public Accountants of China (CICPA), the Institute of Certified Public Taxation Accountants of China (CICTA), the Tax Institute of Hong Kong (HKTI), and the Association of Women Accountants, Cathy supports the practice by sharing her professional wisdom with other practitioners. She is an editor committee member of the China Tax Intelligence (CCH). She also contributes to a wide range of professional institution journals and newspapers. This was recognised by the China M&A Service Awards 2014 that she was honoured with.
Cathy has a close working relationship with Chinese policy makers and officials that comes from her deep understanding of Chinese tax regulation and culture. She spends time in leading or advising many local and regional tax authority initiatives on behalf of PwC, such as engaging the Chinese State Administration of Taxation (SAT) to implement China outbound tax administration and One Belt One Road strategies. In general, Cathy acts as the keystone connector between tax society and authorities.
Mike Jiang, Deloitte China, is a 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.
18/F, PwC Center
Daisy Kang is a tax director of PwC China, Guangzhou Office. She is specialised in providing solutions to clients' tax controversial issues, including tax investigations, tax disputes, tax rulings, applications for favourable tax treatments, etc.
Prior to joining PwC China, she was a tax official of the tax assessment branch of the Xiamen State Tax Bureau.
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 positions which cover a wide spectrum, both income tax, withholding tax, VAT, business tax, real estate tax and transfer pricing matters. She also helped the clients to obtain favourable advanced tax rulings from tax authorities, including tax preferential treatments for the envisaged restructuring, etc.
Throughout the years at the Guangzhou office of PwC China, Daisy has participated in various technical training and workshops conducted by the tax bureaux across China and maintained close contact with the tax officials in major cities in Southern China. Daisy also established good relationships with relevant authorities at the state level, including the State Administration of Taxation (SAT) and the Ministry of Commerce.
Eunice Kuo, Deloitte China, is a tax partner and the national leader for China/Hong Kong cross-border tax services who is in charge of transfer pricing, business model optimisation and tax structuring services.
She has 30 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 of 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 her 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 the best female TP adviser by the Legal Media Group for the Asia Pacific region. Eunice was recently named as the Best of the Best 2013-15 and 2016-18 in the transfer pricing area by the Legal Media Group.
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.
Victor Li, Deloitte China, is the tax managing partner of the southern mainland in China. He is also leading the transfer pricing practice in the southern region. Victor has 15 years of experience in providing transfer pricing services, both in China and the US, helping multinational clients identify and address issues that arise from the increasingly complex transfer pricing regime.
With his extensive experience, Victor has provided an array of transfer pricing services to multinationals, helping them in transfer pricing planning and documentation, as well as managing transfer pricing risk through transfer pricing controversy negotiation and advance pricing agreement (APA) application. Notably, Victor was involved in China's first bilateral APA negotiation. He is also experienced in providing assistance in solving transfer pricing controversy and other related tax controversy matters.
In addition, Victor has helped multinationals in optimising their business model under the increasingly complicated economic environment. He has served a broad spectrum of multinational clients in electronics, information technology, office equipment, pharmaceutical, chemical, beverage, automotive parts, trading services and financial industry, etc.
Victor has been invited to speak at transfer pricing sessions at various conferences sponsored by, among others, the Tax Executives Institute (TEI), Alliance for Tax, Legal and Accounting Seminars (Atlas), United States Council for International Business (USCIB), CCH, and the PEO Group.
Victor has earned a PhD in management, a MBA degree as well as a BA in economics. Victor is a member of the Chinese Institute of Certified Public Accountants (CICPA). He was named continuously as the world leading transfer pricing adviser in 2013 and 2015 by Euromoney.
18/F, PwC Center
Donald Lin is a tax director of PwC China, Guangzhou office, specialising in tax controversy services. Before joining PwC China in early 2016, he gained rich experiences in providing tax services. Donald has over 10 years' experience with the Guangzhou Municipal State Tax Bureau and has worked in another international Big 4 firm for tax controversy services for another seven years.
Donald has rich knowledge in tax laws, policies, and tax administration. He also has extensive practical experiences in the tax controversy services field. He is familiar with China's commercial environment and norms. He has developed good working relationships with the Ministry of Finance, State Administration of Taxation and many other local tax authorities in various regions.
With years of practice, Donald has successfully assisted many multinational and domestic enterprises in different industries to solve their tax controversies with tax bureaus, covering various stages within tax administration cycle, namely tax assessment, tax audit, large enterprise tax audit, outward remittance tax related matters, and tax refunds, as well as applications for tax incentives and policy formulation.
Donald has an MBA and is a qualified CTA from the China Institute.
26/F Office Tower A
Long Ma is a tax partner within the tax controversy service practice based in PwC China, Beijing office.
Long 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 the New York office of PwC US on a secondment during 2006-2008 and was admitted as a partner to the Beijing office of PwC China in July 2014.
Long has close working relationships 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, Long has extensively provided tax service in various fields, including application for tax treaty benefits, mutual agreement procedures (MAP) involving both SAT and local level tax authorities, and defence against the application of the general anti-avoidance rule (GAAR) on cross-border transactions. He has engaged in various cases on tax audit defence, and his proven track record of success in defence has been well recognised by his clients. The experiences gained in these pursuits have proved a valuable resource for the tax controversy services team.
Long graduated from the law school of Peking University with double bachelor's degrees in law and economics. He is a China certified tax agent.
26/F Office Tower A
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, Matthew 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 close working relationships with all of the key departments of the Chinese State Administration of Taxation (SAT). He is often invited to provide advice on the formation of state tax policies.
Because of his 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.
Frank Tang, Deloitte China (Deloitte Touche Tohmatsu Certified Public Accountants), is the China west regional tax leader partner who has dedicated more than 30 years of his professional career to China tax development and practice.
His career started in 1987 when he joined the foreign taxation branch of the Tianjin Municipal State Tax Bureau of China as a tax officer. He is one of the earliest tax officers in China who deals with international taxation after the policy of reform and opening-up has been widely rolled out in China. Frank has handled various important international and domestic tax cases back then and has earned himself wide recognition from taxpayers, the tax authority, and tax professionals.
Frank joined Deloitte in 2001. During the past 16 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, advanced pricing agreements and transfer pricing audit defence, China tax planning, compliance and business advisory. In the meantime, Frank has managed to maintain a very good working relationship with multiple levels of Chinese government authorities, including the tax authority, customs office, Administration of Foreign Exchange, Investment Promotion Bureau, etc. He is also well respected by the government authorities. Since 2009, Frank has led the tax and business advisory practice of Deloitte in Western China. He has established extensive cooperation with the government agencies and tax authorities in Western China including Chongqing, Sichuan, Shaanxi, Guangxi, Guizhou and Yunan.
The proven track record of his practice and his solid technical skills have made Frank highly regarded by his clients. He now represents a significant number of enterprises from multinational companies to small businesses in the fields of manufacturing, servicing, banking, and construction and engineering.
Frank has also been recognised in International Tax Review's Tax Controversy Leaders guide for China for five consecutive years (2013–17), which bases its research on a wide range of interviews with clients and other professional lawyers and advisers.
Frank is also the vice chairman of the Chongqing foreign investment enterprise committee, and director of the Chongqing Tax Institute.
18/F, PwC Center
Janet Xu is a tax partner at PwC China, Guangzhou office. She has over 20 years of tax professional experience, of which 19 years have been in Chinese tax practice.
Janet has substantial experience in advising companies on dealing with tax audits, managing tax disputes on Chinese tax controversy issues, as well as proactively managing tax risks via applications for tax rulings, etc.
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 in 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.
Andrew Zhu, Deloitte China, is the managing partner of the Northern China tax practice and a member of the tax controversy group. He has more than 26 years of experience in Deloitte China and Deloitte US tax practices, and extensive experience in global tax planning, compliance and structuring. He represents large multinational clients in dealing with large tax disputes with the Chinese revenue agencies and customs administration. He also advises China-based companies on handling various tax audits in China and around the world.
Before joining Deloitte China, Andrew had seven years of experience working for the Chinese State Administration of Taxation (SAT, national office). During his tenure with the Chinese tax authority, he undertook senior responsibilities including drafting two of 18 Chinese tax laws and other policies, and served as one of the key representatives from the Chinese tax authorities responsible for 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 the US. 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.
Unit 02, 42/F West Tower
Henry Zhu is a tax partner of PwC China, Suzhou office. He has been providing tax controversy services related to complicated tax disputes since he joined PwC. He is a member of the Certified Tax Agent and Chinese Institute of Certified Public Accountants (CICPA).
Henry has more than 20 years of experience in providing China tax and international tax services to many well-known MNEs and DMIs to resolve tax issues.
Before joining PwC China, Henry worked in the Suzhou Municipal State Administration of Taxation (SAT) for 16 years, focusing on transfer pricing auditing and large-scale enterprises inspections. During this period, Henry was a core member of the transfer pricing team of Suzhou and Jiangsu SAT. He took the leading role in respect of jointly inspecting the national transfer pricing of several industries. He also was a member of the SAT law-making team on special tax adjustments for drafting tax laws, regulations and policies.
Because of his past practices, Henry transformed into an expert on resolving the increasingly complicated tax disputes faced by multinational companies in China supported by his legislative thinking, tax collection management and familiarity of tax audit's methodology and procedures.
Henry has been extensively involved in tax controversy issues such as transfer pricing, equity valuation, indirect-share transferring, business restructuring, intra-group services, beneficial owner identification within a wide range of sectors including logistics, new energy and manufacturing of consumer electronics, automotive, machinery and equipment, home appliances, real estate, etc.
Henry used to provide professional trainings and technical workshops for various tax authorities, and has established extensive and solid relationships with them.
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