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) leading partner based in PwC China's Beijing office, responsible for providing strong support to TCS projects which involve the State Administration of Taxation's (SAT) administration at the state level.

Xiaoying has extensive experience in providing business regulatory and tax advisory services, particularly in the area of turnover taxes, to multinational firms, large state-owned enterprises and private sector companies.

Xiaoying has also worked extensively with publicly traded companies, including assisting these companies with tax compliance issues of pre-IPO organisational restructuring and business realignment, and advising companies on the tax implications of their post listing business expansion and internal control related initiatives.

Before joining PwC, Xiaoying worked in the SAT for more than 15 years. She gained extensive experience, especially in turnover taxes and import and export taxes. She participated in drafting many tax policies related to VAT, export VAT refunds and other tax policies.

Xiaoying has a long-term relationship with SAT and Ministry of Finance. She is also a China Certified Tax Agent.

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 PwC China's Shanghai office.

Between 1994 and 2002, Liang worked in the 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.

After 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, fast-moving consumer goods and real estate among other areas.

Over the years, Liang has achieved various successful outcomes for his clients in tax controversy cases involving a wide range of issues such as: VAT, business tax, export VAT refunds, withholding tax on passive income, permanent establishment, and other tax audit defence cases.

Liang's capacity covers Chinese tax and structure planning, tax negotiation, Chinese indirect tax, tax internal control, foreign contractor advice, tax due diligence and health checks, and tax audit/investigation support.

Liang has a Master of Business Administration 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 chartered tax adviser qualification.

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 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 policy.

Due to this familiarity with the key tax policy makers 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 and the Ministry of Finance. Thus, Matthew's unique calibre has proved to be very helpful in preventing, managing, and resolving tax controversies between taxpayers and the tax policy makers 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.

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

Tianjin 300051

PRC

Tel: +86 22 23206680

Email: jassu@deloitte.com.cn

Jason Su has 26 years of experience in providing multinational and local clients in Tianjin with China tax and business consulting services including tax planning, corporate restructuring, and advice on business and tax issues related to day-to-day operations of foreign investment enterprises. Jason is now the Northern China Japanese Service Group lead partner.

Before joining Deloitte China, Jason served the 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 represents clients in discussions with the Chinese tax authorities in connection with tax disputes and obtaining preference incentives.

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

Tianjin 300051

PRC

Tel: +86 22 23206609

Email: ftang@deloitte.com.cn

Frank Tang is a tax partner with Deloitte China who has dedicated more than 25 years of his professional career to Chinese tax development and practice.

His career started in 1987 at the foreign taxation branch of Tianjin Municipal State Tax Bureau of China as a tax officer. He was one of the first tax officers in China who dealt with international taxation after the policy of reform and opening-up was widely rolled out across China. He handled important international and domestic tax cases and earned wide recognition from taxpayers, tax authorities, and tax professionals.

Frank joined Deloitte in 2001. For the past 12 years he has assisted multinational and domestic clients in properly managing their tax matters. Frank has extensive experience in various tax and business related areas including tax controversy, customs disputes, advance pricing agreement and transfer pricing audit defence, China tax planning, compliance and business advisory.

Frank also maintains a solid working relationship with multiple levels of Chinese government authorities, including the tax authority, customs office, Administration of Foreign Exchange, and Investment Promotion Bureau.

Frank represents a significant number of enterprises, from multinational companies to small business, in the fields of manufacturing, servicing, banking, and construction and engineering.

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 15 years of specialist tax experience in China providing tax advice to multinational companies and domestic companies. Jane is the leading partner of 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. The 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 PwC China's Nanjing branch. She is familiar with the investment and market environment of 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

PRC

Tel: +86 20 3819 2193

Email: janet.xu@cn.pwc.com

Website: pwc.com/taxcontroversy

Janet Xu is a tax partner at PwC China's Guangzhou office. She has 19 years of professional tax experience, of which 14 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 etcetera.

Janet also has extensive experience in providing PRC tax consulting on indirect tax, M&A, and corporate reorganisations 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

PRC

Tel: +86 10 85207511

Email: juliezhang@deloitte.com.cn

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 Chinese 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 and application of tax incentives, among other things.

Julie received her juris doctorate with distinction from Stanford Law School and a bachelor of arts degree from Foreign Affairs College in China. She is licensed to practice 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.