Event Details

Free of Charge 免费参与

AmCham Member Priority 会员优先



活动亮点:

Highlights:


1. 海关和税局转让定价协同价格管理制度

1. Customs and Tax Collaborative Transfer Pricing Management Mechanism


针对长期以来外商企业进口关税和企业所得税双重征税的痛点,结合2022年5月18日出台的海关和税局转让定价协同价格管理制度,以及深圳市税务局制定并推行国际税收事项事先裁定制度,进行政策专业解读、成功案例分享,并建议企业可考虑的安排和行动计划。

Focusing on MNE's long-standing pain points in the double taxation of import tariffs and corporate income tax, and referring to the customs and tax collaborative transfer pricing management mechanism announced on May 18th, 2022 as well as the advance ruling on international taxation issues formulated and implemented by Shenzhen Tax Bureau, this session will cover our professional insight on these regulations, successful case sharing, as well as feasible arrangement and action plans for enterprises.


2. 近期转让定价热点及税局调查动向

2. Recent Transfer Pricing Hot Topics and Investigation Trends of Tax Authority


围绕外商企业常见转让定价风险及税局近期关注重点(包括采购销售服务、进口贸易案例分享),税局调查手段和分析思路,以及企业的应对方法等内容进行分享解读,协助企业更好地识别和管理潜在转让定价风险,了解税局操作规程和分析思路并更好地应对转让定价相关质询和调查

This session will include MNE common transfer pricing risks, recent focus (including sharing of procurement/sales service, import trading case), tax authority's approach and analysis methodology. Also feasible actions plans for enterprises will be covered, so as to assist enterprises identifying and managing potential transfer pricing risks, understand tax authority's operating procedures and analysis methodology in order to better deal with transfer pricing inquiries and investigations.


邀请对象:企业财税负责人或以上级别

Target Audience: Senior finance/tax executive or above of enterprise



语言:中文

Language: Chinese

Speakers

  • Stella Jin (Tax Partner at KPMG)

    Stella Jin

    Tax Partner at KPMG

    Background
    Stella used to work in China Customs and has over 15 years of experiences in the area of customs issues. She has always been dedicated to provide professional services in respect of China tax, customs and foreign exchange to multinational enterprises, comprehensive SOE Groups, and Private-Owned enterprises.
    Professional and Industry Experience
    Stella has over 15 years of experiences in the area of customs issues, including customs valuation practice and customs investigation management, etc.
    She used to work in various core departments of Shenzhen Customs, including Tariff Division, Division of Declaration Documentation Verification, and Clearance Department, etc. She is a specialist in customs classification and other areas including customs valuation, rules of origin, duty exemption, processing trade, import and export control.
    As a professional consultant, she has extensive experience in providing customs services to multinational and domestic companies, e.g. customs classification analysis, transfer pricing planning, supply chain model planning and review, processing trade compliance review, free trade agreement benefit utilization, customs audit defence, tax dispute settlement, enterprises credit rating certification.
    She has served for clients in a wide range of industries, including retail and consumer goods, automotive, electronics, petrochemicals, and telecommunications, etc.

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  • Robert Xu (Tax Partner at KPMG)

    Robert Xu

    Tax Partner at KPMG

    Background
    Robert is the lead partner of Shenzhen office for transfer pricing services. He has over 18 years in-depth professional experience in the area of international tax and transfer pricing advisory.
    Professional and Industry Experience
    He has been managing all aspects of complex transfer pricing projects, including the negotiation of unilateral and bilateral advance pricing agreements, Mutual Agreement Procedure (“MAP”), preparation of three layer TP documentations including Country-by-country reports as per BEPS Action Plan, BEPS 2.0 assessment and implementation, tax efficient supply chain management and implementation including IP planning and migration, TP due diligence in relation to risk review and assessment; business and IP valuations for tax purposes; and TP audit defense.

    Robert has advised hundreds of MNCs with inbound investments in China in relation to transfer pricing issues, In recent years, he also helped number of China MNEs to streamline, plan and develop or enhance and implement their global transfer pricing policies during the process of outbound investment under the evolving macro business environment. His clients cover a wide spectrum of industries such as automobile and parts, TMT, consumer products, shipping and logistics, property development and management, etc.

    In addition to advising clients, Robert is a regular speaker and commentator at business seminars and conferences on China tax and transfer pricing matters and has published articles in various well-known tax and transfer pricing publications in the region. He also acts as a frequent trainer for various tax authorities and professional organizations across China

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  • Lixin Zeng (Tax Director of KPMG)

    Lixin Zeng

    Tax Director of KPMG

    Background
    Lixin Zeng is the pioneer of bilateral APA in China, a former senior expert of the State Administration of Taxation’s National Special Tax Adjustment Major Case Review Panel, a former leader of anti-avoidance area in national tax system. He has over 30 years of experience on transfer pricing practice.

    Professional Experience

    Prior to joining KPMG, Mr. Zeng worked on anti-avoidance sector at Shenzhen Tax Bureau. He handled a series of major and typical tax avoidance cases, and consulted on bilateral APA and cross-country adjustment involving tangible goods, services, intangible assets, and cost sharing agreements. Meanwhile, he was involved in the formulation of anti-avoidance laws, and assisted the tax authorities and multinational enterprises throughout the country in conducting anti-avoidance training. He used to report major cases to State Taxation Administration’s Central Group for Theory Learning and the Conference for National Taxation Directors. In recognition of his outstanding contributions, he was awarded the title of advanced worker in the national and Shenzhen tax administration system.

    He initiated and completed the first and second APA in China (namely the first case between China and Japan and the first case between China and the United States respectively), which hailed as a milestone in international tax administration in China.

    At KPMG, Mr. Zeng is mainly responsible for transfer pricing management in corporates, tax planning for supply chain in groups, defences in anti-avoidance investigation cases and unilateral and bilateral APA. In addition, he has coordinated communication with tax authorities nationwide and has served a large number of foreign companies, state-owned enterprises and private companies, including many of the world’s top 500 enterprises.

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Venue

KPMG

南山区科苑南路2666号中国华润大厦14楼
Floor 14, China Resources Tower, 2666 Keyuan South Road, Nanshan District

Shenzhen, Guangdong, China

If you have any questions please contact Joyce Hu

Contact Organizer

+86 83351476-20

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