Dear Working Group Members,

The European Chamber is delighted to invite you to join the Joint Beijing & Shanghai Finance & Taxation Working Group Meeting: Localization of BEPS Actions in China on Thursday 13:30 -15:30, 14 January 2016 at the European Chamber Beijing Office.

Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit these gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid. BEPS is of major significance for developing counties due to their heavy reliance on corporate income tax, particularly from multinational enterprises (MNEs). 

Following the OECD’s release of ‘2015 Deliverables’ under BEPS initiative, the Chinese State Administration of Taxation (SAT) have set out new guidance which large clarifies how China plans to ‘localize’ the BEPS recommendations.

To offer a comprehensive discussion, the European Chamber has the honor to invite Mr Andrew Choy, Partner, International Tax Services, Ernst & Young, Ms Kena Qu, Senior Manager, Transfer Pricing and Business Advisory, Ernst & Young, and Mr Paul Tang, Partner, Transfer Pricing Services Practice, PwC to deliver a presentation to provide a detailed analysis on this topic.

Agenda:

13:00 – 13:30            Registration

13:30 – 14:30            Presentation: Recent BEPS actions taken by the Chinese tax authorities and impacts on foreign companies doing business and investing in China by Mr Andrew Choy and Ms Kena Qu

14:30 – 15:00            Presentation by Mr Paul Tang

15:00 – 15:30            Q&A and Discussion

This is a member-only working group meeting. Please kindly register online or confirm your registration with Mr. Lingfeng Xu at lfxu@europeanchamber.com.cn.

Mr. Andrew Choy

Partner, International Tax Services, Ernst & Young

Andrew is a China tax partner of the Beijing office. He recently finished his two-year secondment (from 2008 to 2010) to the firm New York office to lead the China tax desk. Andrew specializes in structuring cross border transactions, pre-acquisition tax analysis for PRC investing clients; extensive knowledge in post-acquisition restructuring and integration for multinational companies. From 1997 – 2003, Andrew was based in Hong Kong and specialized in China entrance and pre-investment strategies, tax efficient profits repatriation. From 2004 – 2008, Andrew was based in Beijing with additional focus on China tax advisory for private equity, real estate and venture capital funds. 

Since year 2010, has provided Chinese enterprises with tax strategies and outbound planning associated with their investment, has assisted with its outbound M&A transactions and supported holding structure design, at early stage and operational work related to tax planning at later stage.

Andrew obtained his Bachelor of Business Administration from the University of Washington, Seattle He is a member of the Washington State Board of Accountants.

Ms. Kena Qu

Senior Manager, Transfer Pricing and Business Advisory at Ernst & Young

Kena Qu is a transfer pricing senior manager in Ernst & Young in Beijing. 
Kena joined Ernst & Young as a tax consultant in 2006 and has since gained valuable experience in China transfer pricing and business advisory area. 
In the past ten years, Kena assisted a number of multinational companies in various types of projects, including transfer pricing planning, transfer pricing documentation, risk assessment, transfer pricing audit defense, and advanced pricing agreement (APA). Kena has extensive experience in transfer pricing controversy cases. She was heavily involved in a number of transfer pricing audit cases and several high profile APA cases in China. 

Qualification/Education
Master of Commerce ,University of New South Wales
Bachelor of Economics , Jilin University
Member of CPA Australia

Paul Tang, Partner, Shanghai

Background

Relevant experience

As one of PwC national transfer pricing core members, Paul assisted clients in successfully concluding China's first Mutual Agreement Procedure (“MAP”) with Japan (corresponding adjustment), two of China's first bilateral advance pricing arrangements (“APAs”) with Europe (Denmark), China’s second BAPA with US, China’s first MAP with Norway (corresponding adjustment), and China’s first bilateral APA with Switzerland.

Paul’s recent highlights in terms of transfer pricing audit defence include:

Paul is currently involved in a number of bilateral APA and cross-border corresponding adjustment projects in Beijing, Jiangsu, Shanghai and Tianjin for MNCs from the US and Europe of various industries, as well as state-owned enterprise headquartered in China.

Paul’s major client portfolio includes the companies in the retail and consumer (“R&C”), high technology, and financial services industries.

As a Base Erosion and Profit Shifting (“BEPS”) advisor , Paul is the translator of and responsible for the Chinese version of BEPS Report Action 8-10 (Aligning Transfer Pricing Outcome with Value Creation) and Action 13 (Transfer Pricing Documentation and Country-by-Country Reporting) published by China’s SAT.

Qualifications

Location

Contact