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