China

26/F Office Tower A, Beijing Fortune Plaza

7 Dongsanhuan Zhong Road, Chaoyang District

Beijing 100020

PRC

Tel: +86 10 6533 3018

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 she joined 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 Administration of Taxation (SAT) for 16 years. She worked in several departments of the SAT, including the general office and the goods and services tax (GST) department, among other roles. During that period, Xiaoying participated in the research, drafting and revision of many important tax regulations and she accumulated extensive experience in tax collection and administration. She has deep intelligence regarding China tax and historical development. She 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 provided valuable comments to the MoF and SAT's joint circulars, Caishui [2009] No 59, and the SAT's circular, Guoshuihan [2009] No 698. She pushed forward the issuance of the MoF and SAT's joint circular, Caishui [2012] No 48, and the SAT's Circular Shuizonghan [2013] No 165.

Xiaoying has more than 10 years of experience in professional tax services at PwC. She is a top tax expert, even within PwC, having the relevant working experience in both the SAT and the international accounting firm. She is especially skilled in consulting and coordinating disputes between tax authorities and taxpayers, as well as resolving M&A and capital markets related tax 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 Xiaoying'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. She also helped many famous domestic enterprises resolving their tax issues in relation to overseas-listing, cross-border M&A and privatisation delisting.

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

10th Floor

Shui On Plaza

333 Huai Hai Zhong Road

Shanghai 200021

PRC

Tel: +86 21 23233824

Email: liang.gong@cn.pwc.com

Website: pwc.com/taxcontroversy

Liang Gong is a tax partner in the Shanghai branch of PwC China.

Between 1994 and 2002, Liang worked in the 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. Liang also shared his experience and viewpoints via articles in several national and provincial journals.

Since joining the tax practice, 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 focus includes 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 planning, tax negotiation, China indirect tax, tax internal control, foreign contractor advice, tax due diligence and health checks, tax audit/investigation support, 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.

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

Website: www.deloitte.com

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

Lian-Tang worked in the State Administration of Taxation for more than 28 years and served as chief of the anti-tax avoidance division within the international tax section, and chief of the third office of large enterprise taxation administration section (management of tax risks of large enterprise).

Lian-Tang was the main builder of Chinese transfer pricing regulations. He has been engaged in taxation regarding ocean oil since 1984 and he is a specialist on international tax and tax management, especially on oil taxation.

He has substantial experience in serving multinational clients in the negotiation of APAs and other rulings, formulating internal transfer pricing policy, audit defence, and tax planning.

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

Website: www.deloitte.com

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

Between 1997 and 2008, Mike was with the foreign taxation branch of the 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 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 the fact he held a leadership role for more than five years during his 11-year tenure with the Bureau.

Upon 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, EIT, overseas remittance, permanent establishment, beneficial owner, VAT exemption, and so on.

Since 2002, Mike has become a frequent and favoured 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 and stipulation in Shanghai along the way.

Mike is a certified public accountant and a certified tax agent in China.

18/F, PwC Center, 10 Zhujiang Xi Road

Pearl River New City, Tianhe District

Guangzhou, 510623

PR China

Tel: +86 20 3819 2189

Email: daisy.kang@cn.pwc.com

Website: pwc.com/taxcontroversy

Daisy is a tax director of the Guangzhou branch of PwC China. 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 PwC, 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. She was also extensively involved in reviewing tax audit cases when she was an official at the Xiamen State Tax Bureau, providing 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 moving consumer goods (FMCG) products. She helped these clients in formulating strategies to defend their tax position, covering a wide spectrum of income tax, withholding tax, value added tax, 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 and so on.

During her time at the Guangzhou branch of PwC China, Daisy has participated in various technical training and workshops conducted by the tax bureaus across China and has maintained 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.

Floor 20, Tower B, CICG International Plaza

No.333 North Caoxi Road

Xuhui District

Shanghai

China

Tel: +86 10 65325588

Fax: +86 10 65323768

Email: ykun406@longanlaw.com

Website: www.longanlaw.com

Yang Kun is an expert in tax law, commercial law, corporation and securities law, financial law. He has also worked in the Shanghai Pudong Development Bank for credit management. He is up on project financing, industrial investment and financing, credit financing.

Lawyer Yang Kun has published works including Legal Inquiry of Loan Bank Right of Set-off, Research on Legal Issue of SPV, Legal Character of Employee Share, Legal Concept of Housing Mortgage Loan Securitisation, The New Development of the Maritime Law (translation), and dozens of other articles.

Lawyer Yang Kun has worked as a lawyer for 20 years. He has joined Longan Law firm in the firm's Shanghai branch and has been a chief partner since 2008. Before he joined Longan Law firm, he has been a vice director of a famous law firm in Ningbo, Shanghai Huayi Law firm, and partner lawyer of Jin Mao PRC Lawyers.

Lawyer Yang Kun has graduated from Dongbei University of Finance and Economics (bachelor of laws), East China University of Political Science and Law (master's of law), Tongji University (PhD in technology, economy and management).

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

Website: www.deloitte.com

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

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

Eunice has many years of providing transfer pricing services. She started up Deloitte Taiwan's transfer pricing practice. She has worked for preparation of transfer pricing report, planning for cross-border transactions including supply chain issues, performing transfer pricing due diligence at M&A projects and helping mitigate transfer pricing risk, assisting in settling tax audit cases, helping with conclusion of advance pricing agreements and mutual agreement procedures, and advising on tax issues from business restructure. Eunice has led mutual agreement procedure (MAP) projects and also 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 go through formal tax controversy processes and also has helped clients close tax disputes through negotiation and settlements.

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

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

Unit 7, 20/F Bund Center

222 Yan An Road East

Shanghai 200002

China

Tel: +86 2161411048

Email: mlin@deloitte.com.cn

Website: www.deloitte.com

Martin Lin leads Deloitte China's tax controversy service which consists of more than 30 controversy specialists, former tax officers, and lawyers. Martin is an expert in international taxation and tax risk management and works closely with central and local tax authorities in policy making and dispute resolution. The tax controversy team in China has substantial experience in dealing with defence on anti-avoidance inspection and negotiation, regular tax audits, administrative review, application for rulings and other tax administrative confirmations.

Martin has worked in Deloitte's US and China tax practices in the past 25 years.

8/F, Office Tower E2

Oriental Plaza

Beijing 100738

China

Tel: +86 10 8508 7083

Email: david.ling@kpmg.com

Website: www.kpmg.com/cn/en

David Ling is the tax partner in charge of KPMG Northern China and is based in Beijing. He is a China tax specialist for the industrial and consumer markets sector.

David joined an international accounting firm in the US in 1992 after he obtained his master's degree in US taxation. He transferred to China in 1993 and has worked in offices in Hong Kong, Shenzhen, Shanghai and Beijing. He became a tax partner in 2002 and joined KPMG's Beijing office the same year.

David has extensive experience in Chinese tax planning and tax negotiation. His expertise includes advising foreign companies in establishing operations in China, in particular with the establishment of investment holding companies in China.

David has extensive knowledge of China's customs regulations, foreign exchange control policies, and other regulations which may impact foreign companies' operations in the country.

David has significant relationships with the Chinese authorities, including the Ministry of Commerce, the State Administration for Industry and Commerce, the State Administration for Foreign Exchange, and Customs, as well as the tax authorities at the central and local levels.

26/F Office Tower A, Beijing Fortune Plaza

7 Dongsanhuan Zhong Road, Chaoyang District

Beijing 100020

PRC

Tel: +86 10 6533 3103

Email: long.ma@cn.pwc.com

Website: pwc.com/taxcontroversy

Ma Long is a tax partner within the tax controversy services 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 and was admitted as partner to the Beijing Office of PwC China in July 2014.

Ma has 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 actively participated in various tax exercises, 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 and various tax audit defence exercises. The experiences gained in these pursuits have proved a valuable resource for the tax controversy services 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.

26/F Office Tower A, Beijing Fortune Plaza

7 Dongsanhuan Zhong Road, Chaoyang District

Beijing 100020

PRC

Tel: +86 10 6533 3028

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 more than 20 years of experience in providing Chinese tax and business advisory services to multinationals, and 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 close working relationships 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 tax policies, and is in a strong position to communicate taxpayer views to the SAT. Thus, Matthew's unique skillset and experiences have 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.

30/F, The Exchange North Tower No 1, 189 Nanjing Road, Heping District

Tianjin 300051

PRC

Tel: + 86 22 2320 6680

Email:jassu@deloitte.com.cn

Website: www.deloitte.com

Jason Su has gained 27 years of solid experience in providing multinational and local clients in Tianjin with China tax and business consulting services, which mainly include tax planning, corporate restructuring and advice on business and tax issues related to the day-to-day operations of foreign investment enterprises of various industries. His work has included TEDA Business Consultant, lead partner of YuJiaPu Financial District overall strategic service project, financial risk management and control programme partner of Tianjin Port Free Trade Zone Committee, lead partner of Airbus negotiation, among others.

Before moving to Deloitte Touche Tohmatsu, Jason served on various tax bureaus in Tianjin for more than 11 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.

30/F, The Exchange North Tower 1

189 Nanjing Road

Heping District

Tianjin 300051

PRC

Tel: +86 22 23206609

Email: ftang@deloitte.com.cn

Website: www.deloitte.com

Frank Tang is a tax partner with Deloitte China, who has dedicated his more than 26 years of 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 taxpayers and the tax authority, as well as fellow tax professionals.

Frank joined Deloitte China in 2001. During the past 13 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 dispute, advance pricing agreement and transfer pricing audit defence, China tax planning, compliance and business advisory. In the meantime, Frank has maintained a very good working relationship with multiple levels of PRC government authorities, including the 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 a significant number of enterprises from multinational companies to small businesses in the fields of manufacturing, servicing, banking, and construction and engineering.

In 2013, Frank was recognised in ITR's Tax Controversy Leaders guide, which bases its research on a wide range of nominations from taxpayer clients and other professional lawyers and advisers.

10th Floor

Shui On Plaza

333 Huai Hai Zhong Road

Shanghai 200021

PRC

Tel: +86 21 23232896

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

Website: pwc.com/taxcontroversy

Jane Wang is a tax partner with the Shanghai practice of PwC China. She has more than 16 years of specialist tax experience in China providing tax advice to multinational companies and domestic companies. Jane is the leading partner for tax controversy services for the Central China region.

Through efficient cooperation with clients and the competent government authorities, as well as the tax authorities, Jane successfully helps taxpayers to mitigate potential tax risk, enhance overall tax efficiency and succeed in tax controversy negotiation.

Jane is specialised in providing tax, business and investment consulting services to domestic and overseas clients. These services include tax audit defence, tax ruling application, tax controversy advice and strategy, tax advisory services, restructuring on holding and trading structure, tax planning, mergers and acquisitions support, IPO support, location study, customs and international trade advisory, and tax and operational compliance reviews.

Jane is also the leading partner of the tax department of the Nanjing branch of PwC China. She is familiar with the investment and market environment of the Jiangsu province and has established long-term cooperative relationships with the government authorities in Jiangsu and Nanjing.

Jane is a certified public accountant (CPA) and certified tax agent (CTA). She is also

regularly invited to lecture for various senior executive forums, industry symposia and tax seminars.

18/F, PwC Center, 10 Zhujiang Xi Road

Pearl River New City, Tianhe District

Guangzhou, 510623

P R China

Tel: +86 20 3819 2193

Email: janet.xu@cn.pwc.com

Website: pwc.com/taxcontroversy

Janet is a tax partner at Guangzhou branch of PwC 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 and so on.

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.

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

1 East Chang An Avenue

Beijing 100738

China

Tel: +86 10 85207511

Email: juliezhang@deloitte.com.cn

Website: www.deloitte.com

Julie Zhang is a Deloitte China tax partner based in Beijing, specialising 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, and so on.

Julie received her juris doctorate with distinction from Stanford Law School and bachelor of arts from 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.

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

Website: www.deloitte.com

Andrew Zhu is the partner-in-charge of Deloitte's northern China strategic client tax services group and a member of the tax controversy group. He has more than 24 years of experience in China and in US tax practices, extensive experience on 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 in handling various tax audits.

Before joining Deloitte, 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, but not limited to, 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 US. He is a frequent speaker on 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.