Clients & Cases

Enterprise Tax Incentive Planning and Management

  • Subsidiary of a weapons group company: Advise the application and maintenance of the enterprise income tax incentive, the optimization of the business model from the tax perspective
  • More than 200 enterprises eligible for key support from State in various industries: Advise the clients on the qualification identification of the high-tech enterprises, and the application of the various tax incentive and fiscal subsidies
  • A biodiesel enterprise: Advise the VAT and consumption tax incentive policies applicable to the clients, and the compliance of the tax treatment; assist the client in assessing the possibility of applying for the national finance subsidies; performing high-level tax due diligence
  • A prestigious American university: Advise the clients on the tax exemption application for its China sourced income with State Administration of Taxation, successfully getting the Approval on the Temporary Tax Exemption on Withholding Tax for the Capital Gain Income Derived from the A-share trading in its QFII account from in-charge tax authority

Tax Advice for Major Transaction, M&A

  • A reputable IT company: Advise the PRC tax implications of the offshore acquisition, especially the transaction disclosure liability and the potential PRC tax liability under Circular 698
  • Aforeign funded real estate agency company listed in USA: Advise the alternative structure before IPO and the applicable tax incentive policies
  • A famous PRC trust company: Advise the tax implications of the limited partnership
  • A HK-funded company: Advise the transaction disclosure liability under Circular 698

Real Estate Taxes

  • A real estate CJV: Advise the tax implications of the partners of the CJV for the proposed distribution of the developed buildings and the subsequent transfer, and advise the alternative approaches to mitigate the tax cost of the proposed transactions
  • A real estate EJV: Advise the tax implications of the intended offshore indirect transfer of the EJV and explore tax planning approaches
  • A private real estate company: Tax advice and planning for the proposed reorganization

Finance and M & A

  • Offshore branch of a state-owned bank: Advise the client on the PRC tax implications of proposed Euro Medium Term Program of USD $ 300 million and Debt Instrument Program of USD $ 4 billion
  • A reputable investment bank: Advise the PRC tax implications in connection with the proposed securities lending program
  • A wholly foreign owned finance leasing company: Advise the different tax implications under different finance leasing model; advise the potential impact of the VAT reform trial in Shanghai to finance leasing business
  • A US airline company: Advise the tax implications of the proposed plane transfer

Transfer Pricing & Anti-Avoidance

  • Anonline video enterprise group listed in offshore: Analyze and assess the related-party transactions, assist in formulating the transfer pricing policies and producing of the contemporaneous documents
  • An integrated Circuit EJV: Assist in defensing and negotiating the settlement with the tax authority on the transfer pricing audit for the past 5 years period
  • A lactic acid EJV: Assist in working out the strategy to respond to the tax authority's transfer pricing audit, defending to the preliminary investigation conclusion and negotiating the settlement with tax authority
  • A wholly foreign owned electric company: Analyze and sort out the capital movement among associated companies, assist in negotiating the settlement with the in-charge tax authority

Outbound Investment

  • A state owned company: Advise in the following aspects in connection with its investment in Pakistan for the proposed windfarm and hydropower project: the alternative investment structure, the establishment place of the SPV, the profit repatriation approaches and the exit approaches, the preliminary investigation of the tax law system in destination country
  • A stated owned real estate company for its outbound reorganization project:Advise the alternative structure, the tax implications of the different structure, the establishment place of the SPV
  • A large-scale mineral resource exploration and development company: Advise the application of the enterprise income tax incentive, the cross-border investment structure, the profit repatriation arrangement etc.

Tax Dispute Settlement

  • A state owned company listed in HK: Advise the client on the tax liability of the involved parties in connection with the importation of foreign vessels engaged in the offshore oil exploitation
  • A famous real estate company: Act as the tax advisor to negotiate the settlement for the disputes due to the inflated cost with tax authority
  • A reputable foreign funded lubricating oil manufacture company: Advise the client in connection with the VAT invoice issues arising from the tax audit

Import & Export Taxes

  • A state owned company: Assist the client in restructuring its offshore trading platform with a view to alleviate the import tax cost
  • A wholly foreign owned specialty chemical company: Advise the client on the export VAT refund
  • A domestic private equity fund: Advise the establishment structure of the red wine fund, optimize the import & export process
  • An European offshore oil construction company: Advise the various import & export tax issues in connection with the operation of the offshore oil vessels in different region of the China sea

Individual Tax

  • Chief representative of a foreign company: Advise the PRC IIT implications of the deferred bonus plan granted and enforced offshore by the foreign company
  • Foreign senior manager of a WFOE: Advise the PRC IIT implications of the profit interest plan granted by the foreign parent company
  • Senior managers and the core technology personnel in a domestic company: Advise the alternative stock incentive plan and the IIT implications of stock incentive plan
  • A domestic software company: Advise the tax implications of the valuation adjustment mechanism

Annual Tax Retainer Services

  • An international hotel chain: Advise the PRC IIT implications for considerable individuals during the period of 2008 Beijing Olympics
  • The China headquarters of an international auto manufacturing group: Advise the PRC tax risk management for the clients