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.

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

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.