Hong Kong

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: www.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.

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: www.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 practice 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.

PwC Hong Kong

21/F Edinburgh Tower, The Landmark

15 Queen's Road Central

Hong Kong

Tel: +852 2289 5802

Fax: +852 2810 9888

Email: david.g.smith@hk.pwc.com

Website: www.pwc.com/taxcontroversy

David Smith is a senior adviser to PwC's tax practice in Hong Kong and China.

He commenced his career with the Australian Taxation Office before joining the tax profession in Hong Kong almost 30 years ago. During his career advising on Hong Kong and international tax issues, David has advised many of the world's largest corporate groups, across all industries, on tax planning, structuring and dispute resolution. This has provided David with an enviable understanding of the technical and practical aspects of local and international tax issues.

In his role as a senior adviser to the tax practice, David acts as an experienced resource to assist partners and staff in relation to complex technical issues, dispute resolution and litigation support. As a consequence, he has involvement in a significant number of the firm's clients' major transactions as well as domestic and cross-border tax disputes. Through this work he gains a unique insight into trends regarding issues being scrutinised, attitudes of revenue authorities and methods of dispute resolution.

David also plays important roles in the practice with regard to thought leadership and international tax policy developments and trends. This ensures that the firm is well placed to ensure that its services and advice will withstand the stricter rules and practices which they will be measured against, and the greater transparency which they will face, in the years ahead.

David is a regular speaker and author of articles on tax matters in Hong Kong and China.

Deloitte China

35/F One Pacific Place

88 Queensway

Hong Kong

Tel: +852 2852 6661

Email: raytang@deloitte.com.hk

Website: www.deloitte.com

Raymond Tang, Deloitte China, is a tax partner in the business tax services group. He specialises in Hong Kong, Macau and China tax, including tax planning for corporate restructuring, group re-organisations, IPO tax planning and tax controversy services.

Raymond has 20 years of experience in the tax profession and has extensive experience in dealing with controversy cases for various industries. He has participated in tax controversy cases for retailing groups, manufacturing entities, construction companies, PE funds, etc. In particular, he has solid experience in dealing with controversy cases for clients with cross-border transactions like mainland China, Macau and Hong Kong, by getting personally involved in various negotiations with tax assessors in Hong Kong, Macau, and southern mainland China.

Raymond has been invited to speak at seminars for the Hong Kong Institute of Certified Public Accountants (HKICPA), the Association of Chartered Certified Accountants (ACCA), and various universities in Hong Kong and Macau. He is also the recurring technical reviewer for the Hong Kong Master Tax Guide issued by CCH.

Raymond has a bachelor's degree in professional accountancy from the Chinese University of Hong Kong. He is a member of the Hong Kong Institute of Certified Public Accountants (HKICPA), and a fellow member of the Association of Chartered Certified Accountants (FCCA).

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.