We are tax advisers in China and Hong Kong to both listed and non-listed businesses, as well as multinationals. Our approach is for practical and simple sustainable tax structures. We help you implement such structures, and, if necessary, defend them before tax authorities.
The firm represents clients for cross border transactions, typically for direct investments into China. Planning involves several tax jurisdictions and the applicable tax treaties. Allocating intercompany profits to tax-efficient jurisdictions, as well as income and wealth planning for high net worth individuals are part and parcel of this.
Our diverse experience in the international area extends to corporate, investment, estate planning, financial services, real property, entertainment and licensing of intellectual property rights. We adopt the use of appropriate corporate vehicles and structure business modus using licensing, commissioning, sub-contracting and resale arrangements.
The firm has conducted tax reviews, tax appeals and defence of tax offences against the corporation and its officers in Hong Kong and China. We assist clients in developing case strategy to achieve favorable outcomes, and prepare staff and business policies to manage the business and its senior management in incidences of tax offences in China.
How we can help
- Tax efficient structuring for businesses
- Tax planning for mergers and acquisitions or corporate restructurings
- Transfer pricing planning, economic analysis, documentation, and defence
- Customs duties
- Stamp duty, including voluntary disclosures
- Design and implementation of tax efficient financing structures
- Lobbying on tax matters
- Employment compensation or tax plans
- Succession planning
- Change of residence tax planning
- Real estate acquisitions and development tax planning
Representative experience
Counsel to multi-national snack food group in defence and negotiation of tax charges in PRC in connection with value added tax and regulatory issues concerning invoicing and collection arrangements with distributor, finalised compromise with tax bureau and obtained release of products and agreement as to future practice
Advised multi-national fireworks manufacturer in the restructuring of the shareholding of its Hong Kong operations for US tax purposes and advised on stamp duty saving arrangements
Represented real estate developers in tax appeals and board of review hearings at Hong Kong Inland Revenue Department against charges for profits tax arising from sales and developed strategies to secure decisions in favour of the taxpayer
Counsel to consumer goods MNC on transfer pricing issues and restructure supply chain arrangement
Conducted corporate restructure for a Hong Kong based IT group for asset protection, documented asset and share transfer agreements to segregate tangible/intangible assets and contracts into asset holding companies and trading vehicles respectively
Represented multi-national Thai based trading house in establishment of Hong Kong office and structured contractual and distribution arrangements to minimise exposure to Hong Kong profit tax
Advisers to multi-nationals in devising structures to qualify as CEPA entities under the Closer Economic and Partnership Arrangements between Hong Kong and PRC, prepared applications for approved establishments in PRC arising from such structures and secured customs free exports of products into PRC from Hong Kong