Practice area

World TP Reviews

Transfer pricing
Baker McKenzie

Brendan Kelly is the head of the transfer pricing documentation and defence department at Baker McKenzie. The firm’s practice is comprised of more than 30 partners and associates based in Beijing, Shanghai and Hong Kong. The lawyers and accountants have worked in private practice, accounting firms and private banks. The firm advises clients on the planning and structure of transfer pricing policies, minimising their worldwide tax exposure. The firm also provides services including transfer pricing assessment, review of policies and APAs, pricing models and negotiations with the relevant authorities.

In 2017, Shanwu Yuan helped one client in a matter concerning Mutual Agreement Procedure (MAP). The firm helped the client prepare relevant submissions to enable the successful resolution of the MAP project. The team also worked with the US offices of the firm and assisted the client on both side as the deal between China and US.


Eunice Kuo is the head of the transfer pricing practice at Deloitte. The firm provides a wide range of services, involving transfer pricing advisory and documentation, APAs, examination defence, appeal/litigation and Mutual Agreement Procedures, business model optimisation and facilitation of transfer pricing risk management.

In 2017, Eunice Kuo, Cynthia Chen and Simble Li advised a China-based home appliance industry leader on global transfer pricing documentation services. The team provided services including master file, Country-by-Country Report and global transfer pricing guidelines. The team also provided 65 local reports covering 19 jurisdictions. In addition, the team used Digital Dox and Country by Country Digital Exchange, which assisted the country-by-country report and risk/opportunity assessment.

DLA Piper

Daniel Chan is the head of the transfer pricing practice at DLA Piper. The China transfer pricing team is comprised of lawyers, economists, certified accountants and tax advisers. It works closely with its US and Europe tax team and transfer pricing professionals, assisting clients with transfer pricing issues in domestic and cross-border transactions. It works on BEPS actions development while working with its transfer pricing counterparts across the world. The team participates in the local BEPS action plan implementation, development and interpretation. It has the capability to meet clients’ need for adapting to the BEPS action plan requirements.

In 2017, Windson Li advised a Hangzhou entity on transfer pricing planning. The firm helped the client to set up an intercompany transaction arrangement and pricing policies. In 2018, Daniel Chan, Windson Li and Doris Ho are assisting one firm with the reorganising of a China-Hong Kong intercompany transaction. The team proposed an innovative APA with location-saving analysis to the management, in terms of the global team’s prior APA experience. 

Shan Yu joined the firm as a tax consultant in 2017 and Margaret Tan joined the firm as a senior tax consultant in 2018.


The transfer pricing team at EY is comprised 14 partners, 10 directors and 260 practitioners. The team helps Chinese outbound companies in BEPS compliance such as country-by-country reporting and master filing. They also assist clients with bilateral APA/MAP and domestic transfer pricing audit issues. It is a technology-based solution provider, helping Chinese firms and multinational companies’ regional headquarters to deal with compliance and risk management needs with cost efficiency. 

In 2017, Leonard Zhang helped a Chinese agricultural multinational company to achieve the MAP resolution between China and US. It was the first MAP case of China outbound companies. EY China worked closely with the US team, developing a transfer pricing model that aligns with the business substance of the transaction. In addition, EY also provided a strategy that can be used to apply for a bilateral APA for future transactions and a MAP to deal with the previous transfer pricing adjustment deal.

Grant Thornton

The transfer pricing team at Grant Thornton covers the whole Greater China area. All of the core tax professionals have specialised in transfer pricing practice throughout their careers. They provide a wide range of services, including risk assessment, benchmarking, documentation, dispute resolution, APA and transfer pricing planning. The team also develop transfer pricing training for CFOs and tax managers, explaining transfer pricing regulations and practical solutions.


Cheng Chi is the head of the transfer pricing team at KPMG. The practice provides its clients the following transfer pricing services: audit defence, APA, transfer pricing planning, risk assessment reviews, competent authority procedures, due diligence, value chain analysis, documentation and compliance. The team works with Chinese policymakers in policy consultation, supporting clients in managing transfer pricing litigations and transfer pricing risks. It also helps them regarding BEPS implementation and policy measures.

In 2017, Cheng Chi advised a leading Chinese global oil company on preparing BEPS action 13 compliance service. The team helped the client provide the Country-by-Country Report, master file and local file for the ultimate parent entity of the group. It also assisted the client with the related risk assessment of transfer pricing arrangements.

Larry Li joined as a tax director in transfer pricing and Vivian Zhou joined as a tax director in global mobility services in 2017. Both of them were hired from other big four firms.

WTS China

WTS assists clients with transfer pricing transactions based on the requirements of the Chinese tax authorities. The firm provides services involving preparing transfer pricing studies, conducting benchmarking and ongoing related advices. Its clients include multination groups, national and international medium-sized companies, non-profit organisations and private clients.

In 2018, the team continues to advise Rosen on generate corporate tax, transfer pricing and customs issues. It comments on the client-proposed business model involving pricing methods from a Chinese tax compliance perspective. They also represent the client in its negotiations with the Chinese authorities. 

In 2017, Shelly Meng, who was hired from a big four firm, joined WTS as a consultant.