China

North region leader

PwC China

Beijing

+86 10 6533 3018

xiaoying.chen@cn.pwc.com

pwc.com/taxcontroversy

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.

National tax partner

PwC China

Shanghai

+86 (21) 2323 2580

spencer.chong@cn.pwc.com

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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.

Central region tax controversy partner

PwC China

Shanghai

+86 21 2323 3824

liang.gong@cn.pwc.com

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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.

South region partner

PwC

+852 2289 5659

cathy.kai.jiang@hk.pwc.com

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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.

North region senior counsel

Rui Bai Law Firm / PwC

Beijing

+86 (10) 8540 4670

yimin.kou@ruibailaw.com

www.ruibailaw.com

Ms. Yimin Kou is a Senior Counsel of Rui Bai, an independent firm and member of the PwC global network of firms. She graduated from the Law School of Peking University (LL.M) and obtained her Master's degree from the International Tax Centre of Leiden University (Master in International Tax Law). Prior to joining Rui Bai, Yimin worked in a Big Four firm in China, the Beijing representative office of an Italian law firm and a domestic law firm. She is a China-qualified lawyer and a member of IFA, is a Chinese native and is also fluent in English.

Yimin has more than 10 years' experience on the provision of legal and tax advice on cross-border group structuring, M&A, transfer pricing, non-resident taxation and CRS. In recent years she has been focusing on tax disputes issues, including tax administrative reconsideration, tax administrative litigation, pre-tax reconsideration legal services (including special tax adjustments investigation, such as transfer pricing and GAAR, and general tax audit).

Yimin specialises in handling complicated tax cases. Thanks to her deep knowledge in law and rich understanding of taxation she has represented a number of listed companies, foreign invested enterprises, and individual entrepreneurs in tax disputes issues. Among them, in 2015 and 2018, she acted as the lead counsel against the Chinese State Administration of Taxation in two tax administrative reconsideration cases (transfer pricing) – the first two cases of their kind in China – and secured the results in favour of the clients. Currently, she works very closely with PwC China Tax to provide independent legal support on tax dispute issues.

Yimin also frequently contributes articles to foreign professional publications, including "Departures from the OECD MC and Commentaries on EU Law and Tax Treaties from Chinese Prospective as a Country Report" and "Impact of the Chinese VAT Pilot on the International Freight Forwarding Industry and the International Shipping Industry", published in IBFD Book and the World Journal of VAT/GST Law respectively.

South region tax director

PwC China

Guangzhou

+86 20 3819 2552

donald.lin@cn.pwc.com

pwc.com/taxcontroversy

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.

North region tax partner

PwC China

Beijing

+86 10 6533 3103

long.ma@cn.pwc.com

pwc.com/taxcontroversy

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.

National leader

PwC China

Beijing

+86 (10) 6533 3028

matthew.mui@cn.pwc.com

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, 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.

Central region tax partner

PwC China

+86 21 2323 8292

andy.sun@cn.pwc.com

pwc.com/taxcontroversy

Andy Sun is a tax partner with the Shanghai practice of PwC China. He has more than 12 years of specialist tax experience in China providing tax advice to multinational and domestic companies.

His expertise includes:

• Tax controversy services such as indirect transfer (exit support for a top-five China real property industry player), restructuring implementation support (red-chip restructuring, etc.), tax audit defense, treaty benefit applications, etc.

• Corporate restructuring on holding structures and business models

• Tax planning and tax effectiveness analysis for group companies

• M&A support

Although Andy has no tax official background, he has successfully established his personal connections widely with many Chinese tax bureaus at all levels, from SAT to local district. He has experience of different functions, from international tax departments, income tax departments, turnover tax departments, tax administration department, etc., and in different regions, from Central China provinces to North / South provinces such as Hainan, Guangdong, Guangxi, Yunnan, Gansu, Ningxia, Beijing, Tianjin, etc. He also actively serves as speaker in many classes and seminars organized by tax authorities.

All of the above helps Andy achieve deep insights with regard to tax policy and the motivation behind tax audits, and gives him the ability to identify the right tax officials to open constructive dialogues and monitor the dispute case process towards a positive outcome.

Over his professional career so far, Andy has gathered extensive experience in serving a wide spectrum of clients in various industries, including real property, FMCG, internet, foreign contractor, chemical, automobile, transportation, advertisement, engineered products, etc.

Andy received his Master's degree from Shanghai Jiaotong University in China. He is also a member of the Chinese Institute of Certified Tax Agent.

Central region tax partner

PwC

Suzhou

+86 (512) 6273 1917

henry.hp.zhu@cn.pwc.com

pwc.com/taxcontroversy

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.