Hong Kong

August 16, 2017

Colin Farrell
	PwC Hong Kong 21/F Edinburgh TowerThe Landmark 15 Queen's Road Central Hong Kong Tel: +852 2289 3800 Fax: +852 2810 9888 Email: colin.farrell@hk.pwc.com Website: pwc.com/taxcontroversy Colin Farrell has more than 37 years of professional experience in Hong Kong and London, with the last 23 being in Hong Kong. In the tax area, Colin is unusually, and probably uniquely, recognised by his external peers in three quite distinct areas: transfer pricing, tax disputes, and international tax, with a growing additional recognition in M&A. He is twice recognised as one of the expert transfer pricing practitioners in Hong Kong by the Transfer Pricing Expert Guide, and further recognised by Acquisition International in its 2015 M&A Awards as 'Best for Transfer Pricing – Hong Kong' (as well as 'Tax Expert of the Year – Hong Kong'). He is also recognised, for the third time in succession, as a leading dispute resolution expert by International Tax Review's Tax Controversy Leaders guide (having previously been recognised by International Tax Review as "among the firm's leading lights for tax controversy in Asia"). He is also named, for the fourth time in succession, as one of the pre-eminent international tax practitioners in Asia by Euromoney's Tax Advisers Expert Guide. Additionally, Colin was recognised in 2016 as 'Corporate Tax Adviser of the Year in Hong Kong' in CIM's global awards. In Hong Kong, Colin services a wide range of clients, who range from individuals to the major MNEs. He acts as general global tax coordinator for a number of these, and as global/ regional coordinator for major due diligences. He also regularly spends very significant time on non-tax consulting and general business issues with his clients, and is the global relationship partner on all matters with a few of these. Colin has spoken and published extensively, including his own entirely external and well regarded personal publications. Colin has a MA in economics from Cambridge University, and is a fellow of the HKIC-PA, ICAEW & TIHK. He is a certified tax adviser and international tax examiner. Outside of work, Colin sits on the joint liaison committee on taxation, is a twice-appointed member of the HKSAR's public affairs forum, and a board of advisers member of International Care Ministries.

Colin Farrell

PwC Hong Kong

21/F Edinburgh TowerThe Landmark

15 Queen's Road Central

Hong Kong

Tel: +852 2289 3800

Fax: +852 2810 9888

Email: colin.farrell@hk.pwc.com

Website: pwc.com/taxcontroversy

Colin Farrell has more than 37 years of professional experience in Hong Kong and London, with the last 23 being in Hong Kong.

In the tax area, Colin is unusually, and probably uniquely, recognised by his external peers in three quite distinct areas: transfer pricing, tax disputes, and international tax, with a growing additional recognition in M&A. He is twice recognised as one of the expert transfer pricing practitioners in Hong Kong by the Transfer Pricing Expert Guide, and further recognised by Acquisition International in its 2015 M&A Awards as 'Best for Transfer Pricing – Hong Kong' (as well as 'Tax Expert of the Year – Hong Kong'). He is also recognised, for the third time in succession, as a leading dispute resolution expert by International Tax Review's Tax Controversy Leaders guide (having previously been recognised by International Tax Review as "among the firm's leading lights for tax controversy in Asia"). He is also named, for the fourth time in succession, as one of the pre-eminent international tax practitioners in Asia by Euromoney's Tax Advisers Expert Guide. Additionally, Colin was recognised in 2016 as 'Corporate Tax Adviser of the Year in Hong Kong' in CIM's global awards.

In Hong Kong, Colin services a wide range of clients, who range from individuals to the major MNEs. He acts as general global tax coordinator for a number of these, and as global/ regional coordinator for major due diligences. He also regularly spends very significant time on non-tax consulting and general business issues with his clients, and is the global relationship partner on all matters with a few of these.

Colin has spoken and published extensively, including his own entirely external and well regarded personal publications.

Colin has a MA in economics from Cambridge University, and is a fellow of the HKIC-PA, ICAEW & TIHK. He is a certified tax adviser and international tax examiner.

Outside of work, Colin sits on the joint liaison committee on taxation, is a twice-appointed member of the HKSAR's public affairs forum, and a board of advisers member of International Care Ministries.

Angela Ho
	PwC Hong Kong 21/F Edinburgh TowerThe Landmark 15 Queen's Road Central Hong Kong Tel: +852 2289 3860 Fax: +852 2810 9888 Email: angela.ym.ho@hk.pwc.com Website: pwc.com/taxcontroversy Angela Ho is the associate director of the tax controversy services group of PwC Hong Kong. She serves a wide range of clients including multinational enterprises and Hong Kong enterprises mainly in the retail and consumer products, manufacturing and apparel industries. Angela has gained more than 25 years' solid experience in providing advisory services to her clients involving tax dispute resolution with the Hong Kong Inland Revenue Department (IRD). Before joining PwC Hong Kong, she served at the IRD for six years, four of which were with the profits tax and tax investigation unit. She is very knowledgeable about the IRD's practices and procedures, which facilitates her negotiation and tax resolution with the IRD. Angela also has extensive experience in tax advisory, including business restructuring, offshore profits claim, health checks and post audit risk management. Angela is a frequent speaker at seminars organised by various professional bodies in Hong Kong. Angela is a member of the Hong Kong Institute of Certified Public Accountants, the Association of Chartered Certified Accountants, the Chartered Professional Accountants of British Columbia and the Hong Kong Institute of Chartered Secretaries. She is a graduate of the Hong Kong Polytechnic University.

Angela Ho

PwC Hong Kong

21/F Edinburgh TowerThe Landmark

15 Queen's Road Central

Hong Kong

Tel: +852 2289 3860

Fax: +852 2810 9888

Email: angela.ym.ho@hk.pwc.com

Website: pwc.com/taxcontroversy

Angela Ho is the associate director of the tax controversy services group of PwC Hong Kong. She serves a wide range of clients including multinational enterprises and Hong Kong enterprises mainly in the retail and consumer products, manufacturing and apparel industries. Angela has gained more than 25 years' solid experience in providing advisory services to her clients involving tax dispute resolution with the Hong Kong Inland Revenue Department (IRD). Before joining PwC Hong Kong, she served at the IRD for six years, four of which were with the profits tax and tax investigation unit. She is very knowledgeable about the IRD's practices and procedures, which facilitates her negotiation and tax resolution with the IRD.

Angela also has extensive experience in tax advisory, including business restructuring, offshore profits claim, health checks and post audit risk management.

Angela is a frequent speaker at seminars organised by various professional bodies in Hong Kong.

Angela is a member of the Hong Kong Institute of Certified Public Accountants, the Association of Chartered Certified Accountants, the Chartered Professional Accountants of British Columbia and the Hong Kong Institute of Chartered Secretaries. She is a graduate of the Hong Kong Polytechnic University.

Philip Hung
	PwC Hong Kong 21/F Edinburgh Tower The Landmark 15 Queen's Road, Central Hong Kong Tel: +852 2289 3130 Fax: +852 2810 4690 Email: philip.ft.hung@hk.pwc.com Website: pwc.com/taxcontroversy Philip Hung is a director of the tax controversy group in PwC Hong Kong. He has more than 34 years of experience in Hong Kong taxation, of which six years he worked in the Hong Kong Inland Revenue Department (IRD) including in the field audit and investigation unit. After leaving the IRD, Philip concentrated in developing the PwC tax controversy services. He assisted in the setting up of the specialised tax investigation and field audit division within the firm. The firm has become one of the leading tax controversy advisers in Hong Kong. Throughout these years, Philip has assisted numerous clients to resolve their tax controversy cases, clients including multinational companies, large Hong Kong listed companies, and also small and medium sized enterprises from different industries. Being an ex-IRD officer and the past president of the Taxation Institute of Hong Kong, Philip is able to establish effective communications with the IRD. Furthermore, by focusing in the specialised tax controversy area, Philip has gained vast experiences in resolving a lot of tax disputes with the IRD, not only on tax audit and investigation cases, but tax appeal cases as well. Philip adopted a proactive approach in handling tax disputes. He believes that to take a practical approach by bringing the case to the IRD, rather than waiting for the IRD to come once the audit commences, is a best way to defend an IRD dispute. Issues resolved by him include cross-border disputes, capital and revenue queries, etc. He also collaborated with other industry experts in PwC to resolve complex cases such as transfer pricing audits and tax audits on the fund management industries. He is recognised as the guru of the tax controversy industries in Hong Kong. Philip has contributed numerous articles to newspapers and magazines. He also gives regular talks to professional, trade and business associations on the topic. He is the sensei and shifu to a lot of Hong Kong tax professionals in the tax controversy area who have attended his annual four-day seminar on tax audit resolution held by the Taxation Institute of Hong Kong.

Philip Hung

PwC Hong Kong

21/F Edinburgh Tower

The Landmark

15 Queen's Road, Central

Hong Kong

Tel: +852 2289 3130

Fax: +852 2810 4690

Email: philip.ft.hung@hk.pwc.com

Website: pwc.com/taxcontroversy

Philip Hung is a director of the tax controversy group in PwC Hong Kong. He has more than 34 years of experience in Hong Kong taxation, of which six years he worked in the Hong Kong Inland Revenue Department (IRD) including in the field audit and investigation unit. After leaving the IRD, Philip concentrated in developing the PwC tax controversy services. He assisted in the setting up of the specialised tax investigation and field audit division within the firm. The firm has become one of the leading tax controversy advisers in Hong Kong. Throughout these years, Philip has assisted numerous clients to resolve their tax controversy cases, clients including multinational companies, large Hong Kong listed companies, and also small and medium sized enterprises from different industries.

Being an ex-IRD officer and the past president of the Taxation Institute of Hong Kong, Philip is able to establish effective communications with the IRD. Furthermore, by focusing in the specialised tax controversy area, Philip has gained vast experiences in resolving a lot of tax disputes with the IRD, not only on tax audit and investigation cases, but tax appeal cases as well. Philip adopted a proactive approach in handling tax disputes. He believes that to take a practical approach by bringing the case to the IRD, rather than waiting for the IRD to come once the audit commences, is a best way to defend an IRD dispute. Issues resolved by him include cross-border disputes, capital and revenue queries, etc. He also collaborated with other industry experts in PwC to resolve complex cases such as transfer pricing audits and tax audits on the fund management industries.

He is recognised as the guru of the tax controversy industries in Hong Kong. Philip has contributed numerous articles to newspapers and magazines. He also gives regular talks to professional, trade and business associations on the topic. He is the sensei and shifu to a lot of Hong Kong tax professionals in the tax controversy area who have attended his annual four-day seminar on tax audit resolution held by the Taxation Institute of Hong Kong.

Kaiser Kwan
	PwC Hong Kong 21/F Edinburgh Tower, The Landmark 15 Queen's Road Central Hong Kong Tel : +852 2289 3868 Fax : +852 2289 9888 Email : kaiser.kwan@hk.pwc.com Website: pwc.com/taxcontroversy Having joined PwC Hong Kong in April 2012, Kaiser Kwan is a tax partner-in-charge of the field audit and investigation team in PwC Hong Kong. He commenced his career with the Hong Kong Inland Revenue Department, followed by more than 20 years of experience in Big 4 firms. He is a seasoned tax professional, with extensive experience in operational restructuring and cross-border tax advisory services. Since 1998, he has focused on the expertise in tax controversy. Leading a specialised team, he has helped many companies in different industries which run from sole proprietors to multinational companies and cover different industry categories, such as financial services and funds, manufacturing, retail chain, as well as fashion and jewellery business, in settling their tax field audit investigation. Over the years, he has developed a unique profile as a highly respected tax controversy expert in the Hong Kong market and has assisted many renowned companies to settle their disputes with the tax authorities. He is a fellow member of the Hong Kong Institute of Certified Public Accountants (HKICPA) and the Association of Chartered Certified Accountants. International Tax Review named him as one of the top tax advisers in Hong Kong and the Chinese Mainland in 2002, 2003, 2007 and 2010. ITR also named him as a leading individual in Hong Kong in cross-border structuring in World Tax 2005. He was named as one of the world's leading tax advisers as featured in the 2007 Legal Media Group Expert Guides publication. He participates in public seminars and forums organised by professional organisations and business associations on cross-border taxation, field audit and tax investigation matters. He also regularly contributes articles on Hong Kong taxation issues and is frequently interviewed by the financial press in Hong Kong.

Kaiser Kwan

PwC Hong Kong

21/F Edinburgh Tower, The Landmark

15 Queen's Road Central

Hong Kong

Tel : +852 2289 3868

Fax : +852 2289 9888

Email : kaiser.kwan@hk.pwc.com

Website: pwc.com/taxcontroversy

Having joined PwC Hong Kong in April 2012, Kaiser Kwan is a tax partner-in-charge of the field audit and investigation team in PwC Hong Kong. He commenced his career with the Hong Kong Inland Revenue Department, followed by more than 20 years of experience in Big 4 firms. He is a seasoned tax professional, with extensive experience in operational restructuring and cross-border tax advisory services. Since 1998, he has focused on the expertise in tax controversy. Leading a specialised team, he has helped many companies in different industries which run from sole proprietors to multinational companies and cover different industry categories, such as financial services and funds, manufacturing, retail chain, as well as fashion and jewellery business, in settling their tax field audit investigation. Over the years, he has developed a unique profile as a highly respected tax controversy expert in the Hong Kong market and has assisted many renowned companies to settle their disputes with the tax authorities.

He is a fellow member of the Hong Kong Institute of Certified Public Accountants (HKICPA) and the Association of Chartered Certified Accountants. International Tax Review named him as one of the top tax advisers in Hong Kong and the Chinese Mainland in 2002, 2003, 2007 and 2010. ITR also named him as a leading individual in Hong Kong in cross-border structuring in World Tax 2005. He was named as one of the world's leading tax advisers as featured in the 2007 Legal Media Group Expert Guides publication. He participates in public seminars and forums organised by professional organisations and business associations on cross-border taxation, field audit and tax investigation matters. He also regularly contributes articles on Hong Kong taxation issues and is frequently interviewed by the financial press in Hong Kong.

Kenneth Wong
	PwC Hong Kong 21/F Edinburgh Tower The Landmark 15 Queen's Road Central Hong Kong Tel: +852 2289 3822 Fax: +852 2521 3161 Email: kenneth.wong@hk.pwc.com Website: pwc.com/taxcontroversy Kenneth Wong is a tax partner of PwC Hong Kong and is the leader of the Hong Kong tax controversy services (HK TCS) practice. He has 20 years of experience in tax consulting and is specialised in helping clients resolve complex tax controversial issues with the Hong Kong Inland Revenue Department (IRD). Kenneth has significant HK TCS experience and successfully helped many multinational and listed companies settle tax disputes and board of review cases with different technical units within the IRD, including appeals, field audit and investigation, tax treaty, etc., on various technical issues like offshore claims, transfer pricing, tax anti-avoidance, and complex cross-border tax issues involving tax treaties between the IRD and overseas tax authorities. His clients include multinational corporations, HK listed companies and Chinese enterprises mainly in the consumer and industrial products, retailing and technology industries. Kenneth is a regular speaker in public tax events. He also made regular contributions to the government through his external duties. He is the co-chairman of the tax sub-committee of the Association of Chartered Certified Accountants Hong Kong (ACCA HK) and helps the ACCA HK make budget submissions to the government and give recommendations to improve the HK tax systems every year. He attended the finance committee meeting in the Legislative Council to comment on certain draft tax bills. In 2015, he spoke together with the deputy commissioner of the China State Administration of Taxation and the IRD commissioner on BEPS development in China and Hong Kong. Kenneth is also a tax expert on international tax and mergers and acquisitions. In 2006, he was seconded to PwC Belgium to establish the China/HK desk there at that time. Kenneth graduated from the Chinese University of Hong Kong. He is committee member of The Association of Chartered Certified Accountants, past president of Institute of Accountants Exchange, honorary committee member of the China Certified Tax Agents Association, Hong Kong Certified Tax Adviser, member of The Hong Kong Institute of Certified Public Accountants and Taxation Institute of HK.

Kenneth Wong

PwC Hong Kong

21/F Edinburgh Tower

The Landmark

15 Queen's Road Central

Hong Kong

Tel: +852 2289 3822

Fax: +852 2521 3161

Email: kenneth.wong@hk.pwc.com

Website: pwc.com/taxcontroversy

Kenneth Wong is a tax partner of PwC Hong Kong and is the leader of the Hong Kong tax controversy services (HK TCS) practice. He has 20 years of experience in tax consulting and is specialised in helping clients resolve complex tax controversial issues with the Hong Kong Inland Revenue Department (IRD).

Kenneth has significant HK TCS experience and successfully helped many multinational and listed companies settle tax disputes and board of review cases with different technical units within the IRD, including appeals, field audit and investigation, tax treaty, etc., on various technical issues like offshore claims, transfer pricing, tax anti-avoidance, and complex cross-border tax issues involving tax treaties between the IRD and overseas tax authorities.

His clients include multinational corporations, HK listed companies and Chinese enterprises mainly in the consumer and industrial products, retailing and technology industries.

Kenneth is a regular speaker in public tax events. He also made regular contributions to the government through his external duties. He is the co-chairman of the tax sub-committee of the Association of Chartered Certified Accountants Hong Kong (ACCA HK) and helps the ACCA HK make budget submissions to the government and give recommendations to improve the HK tax systems every year. He attended the finance committee meeting in the Legislative Council to comment on certain draft tax bills. In 2015, he spoke together with the deputy commissioner of the China State Administration of Taxation and the IRD commissioner on BEPS development in China and Hong Kong.

Kenneth is also a tax expert on international tax and mergers and acquisitions. In 2006, he was seconded to PwC Belgium to establish the China/HK desk there at that time.

Kenneth graduated from the Chinese University of Hong Kong. He is committee member of The Association of Chartered Certified Accountants, past president of Institute of Accountants Exchange, honorary committee member of the China Certified Tax Agents Association, Hong Kong Certified Tax Adviser, member of The Hong Kong Institute of Certified Public Accountants and Taxation Institute of HK.

Philip Wong
	Deloitte China 35/F, One Pacific Place 88 Queensway Hong Kong Tel: +852 2852 1004 Fax: +852 2854 2979 Email: phiwong@deloitte.com.hk Website: www.deloitte.com Philip Wong, Deloitte China, is a partner in the international and M&A tax services group and the lead transfer pricing partner in the Hong Kong office. He has a strong background in corporate taxation, spanning some 30 years, including prior professional experience with Deloitte's Hong Kong office, the Inland Revenue Department and as the regional tax director in a multinational enterprise. Philip specialises in a wide range of areas, including Hong Kong taxation, cross-border transactions between Hong Kong and China, inbound investment strategies into Hong Kong and China, transfer pricing management, pre-listing tax planning and restructuring, regional tax planning and group reorganisation, and M&As in an international context. Philip's distinguished career has equipped him with comprehensive skills and competence in serving MNEs that have various forms of investment in the Asia Pacific region and advising them on transfer pricing planning, supply chain optimisation, R&D/headquarter/regional cost sharing arrangements, and tax-efficient structuring for cross-border supply chain transactions. Philip has advised clients in a wide range of industries, including the real estate, pharmaceuticals, apparel, electronics, telecommunications, financial services, entertainment, and manufacturing sections. Philip has been recognised consistently as a leading transfer pricing adviser in Hong Kong in Euromoney's Transfer Pricing Expert Guide in 2009, 2011, 2013 and 2015.

Philip Wong

Deloitte China

35/F, One Pacific Place

88 Queensway

Hong Kong

Tel: +852 2852 1004

Fax: +852 2854 2979

Email: phiwong@deloitte.com.hk

Website: www.deloitte.com

Philip Wong, Deloitte China, is a partner in the international and M&A tax services group and the lead transfer pricing partner in the Hong Kong office. He has a strong background in corporate taxation, spanning some 30 years, including prior professional experience with Deloitte's Hong Kong office, the Inland Revenue Department and as the regional tax director in a multinational enterprise.

Philip specialises in a wide range of areas, including Hong Kong taxation, cross-border transactions between Hong Kong and China, inbound investment strategies into Hong Kong and China, transfer pricing management, pre-listing tax planning and restructuring, regional tax planning and group reorganisation, and M&As in an international context.

Philip's distinguished career has equipped him with comprehensive skills and competence in serving MNEs that have various forms of investment in the Asia Pacific region and advising them on transfer pricing planning, supply chain optimisation, R&D/headquarter/regional cost sharing arrangements, and tax-efficient structuring for cross-border supply chain transactions. Philip has advised clients in a wide range of industries, including the real estate, pharmaceuticals, apparel, electronics, telecommunications, financial services, entertainment, and manufacturing sections.

Philip has been recognised consistently as a leading transfer pricing adviser in Hong Kong in Euromoney's Transfer Pricing Expert Guide in 2009, 2011, 2013 and 2015.