World TP Reviews

Transfer pricing
Baker McKenzie

Abe Zhao is the head of transfer pricing practice at Baker McKenzie. The tax team is comprised of more than 30 practitioners based in Beijing, Hong Kong and Shanghai. It assists the clients with the planning and structure of a transfer pricing policy that minimizes the worldwide tax exposure, also with transfer pricing risk assessments, review of policies and advance pricing agreements, pricing models and negotiations with the relevant authorities.

Details of the firm’s work and clients remains confidential.


The tax team is led by partner Omar Puertas, and it covers all types of tax advice for companies based in China from a range of sectors, especially automotive, industrial engineering, chemicals and life sciences. It also advises leading Spanish and Portuguese companies, and recently Latin American companies, on their investments in China and in other countries in Asia.

The team recently advised on the daily operation of the client’s subsidiary in China and their intra-group transactions, as well as collaborating with the Spanish team to design their global transfer pricing policy. It also advises individual income tax in China relating to expatriates working in China.


Deloitte offers a broad range of fully integrated tax services, covering both cross-border and local issues from multinational and local clients across various industries. Tax services cover business tax, international tax, transfer pricing, tax management consulting, M&A, indirect tax.

Eunice Kuo led the team and acted as a transfer pricing and direct tax adviser for the client and assisted with technical advisory, communication with tax authority, and coordinated tax adviser for indirect tax part.

DLA Piper

Windson Li is the co-head of tax department at DLA Piper China. His practice covers corporate tax, tax controversy, transfer pricing and customs. The tax team provides services including indirect tax, transactional tax and tax disputes. The team works closely with Hong Kong team to meet clients’ business needs. In the last year, it continued the development and expansion of a wide range of specialized tax practices such as transfer pricing, executive compensation, private banking, personal tax planning.

Details of the firm’s recent work and clients remain confidential.


The EY transfer pricing team comprises of 14 transfer pricing partners, 14 directors and 330 dedicated transfer pricing practitioners in China. It has developed a new transfer pricing automation tool integrated with EY China Tax team’s integration platform, which improves the efficiency of transfer pricing compliance exercise and facilitates effective transfer pricing assessment review and risk management.

The team recently advised the client with the reasonableness of the related-party transactions from mainland China transfer pricing perspective. It provided transfer pricing assessment and planning to enhance the compliance status of the client during its IPO process, also conducted transfer pricing analyses on the historical transactions and valuation analyses for future transactions.


JunHe has professionals based in Beijing, Shanghai and Guangzhou. It has a strong capability in advising on the PRC tax implications of inbound and outbound M&A. In addition, its practice also covers indirect tax, disputes and litigation. The team has a good relationship with local tax authorities so as to understand the tax policies and the rationale behind them. It helps a wide range of clients, including ExxonMobil, NXP, Aramco, Everbright Investment, MFP, Bosch and Sa.

Recent examples of the firm’s work include acting as a legal counsel for the client, Samsung Display Co Ltd Korea. This matter is significant as it covers many countries and regions around the world and have considerable scale, the deal is subject to the reviews and approvals from the investment and anti-monopoly authorities of the PRC, the ROK and other countries.

WTS China

WTS China is a full-service specialist in tax advisory related to investments in China and Germany. It supports global, large-scale enterprises and medium-sized firms. It maintains excellent contacts to the Financial Administration Bureau of the People’s Republic of China. Managing partner Martin Ng covers corporate tax risk controlling practice.

The team provided transfer pricing support to a Germany-invested scientific instruments manufacturer in China. The work includes supporting the client to analyse the group transfer pricing policy and comment the China transfer pricing risk, assisting the client to clarify the reasonableness of the intercompany pricing and to prepare documents to convince the tax authority.