Article contributors

Soraia Almeida

Senior Manager, Corporate Tax, KPMG

Qualifications

Bachelor of Laws (LL.B), Lisbon University Master of Business and Law, CATOLICA Lisbon, School of Business & Economics Advanced Diploma in International Taxation, CIOT

Professional experience

Soraia has over 8 years’ experience focusing on cross-border taxation matters and advising clients on both inbound and outbound investment structuring in the Asia Pacific region. Prior to relocating to Hong Kong, Soraia worked in the corporate and international tax departments of KPMG Thailand, KPMG Vietnam and KPMG Portugal. Soraia has extensive experience of advising international corporate investors, financial services and governmental (profit and non-profit) organisations on their investments and operations across Asia, including advising clients on tax and regulatory considerations on market entry, tax-efficient structuring of their transactions, and assist with international tax planning advice in relation to intellectual property, financing, cross-border migrations, global supply chains and use of tax incentives. Building from her law and business background, Soraia has acted lead tax manager in large inbound investment projects into Thailand, Vietnam and other southeast Asian jurisdictions through Hong Kong, including assisting with tax and legal due diligence procedures, structuring and review of key investment documentation such as Share Purchase Agreements.

Darren Bowdern

Partner, Deal Advisory, M&A Tax Head of Alternative Investments, KPMG

Qualifications

Bachelor of Commerce, University of Melbourne Fellow member, HKICPA Member, CA ANZ

Professional involvements

Director, AustCham, Hong Kong and Macau Vice-Chair, Finance, Legal and Tax Committee, AustCham Vice-Chair, Technical Committee, HKVCA Member, Tax Committee, AIMA Committee member, Tax and Financial Services Working Group, FSDC

Professional experience

Darren has more than 25 years’ experience of serving institutions in a wide range of industries in Hong Kong and Asia Pacific.

Darren heads up the M&A Tax practice in Hong Kong. He has been advising on transactions in Asia Pacific with respect to tax matters, including due diligence reviews, investment holding structures and advising on cross border transactions. Many of these projects comprise of tax effective regional planning including consideration of direct and indirect taxes, capital and stamp duties, withholding taxes and the effective use of double taxation agreements. Darren also advises on establishing direct investment, private equity and other investment funds in Hong Kong and advises clients in a wide range of industries. Darren specializes in cross-border buy and sell-side M&A tax services (e.g. Tax Due Diligence, Tax Vendor Due Diligence), tax structuring, tax planning and optimization and international corporate tax issues, restructuring and optimization. Darren has extensive experience in working with the mainland Chinese market, including structuring acquisitions of investments in China.

Peter Brewin

Partner, Financial Services Transfer Pricing, PwC

Qualifications

Chartered Accountant, ICAEW

Professional experience

Peter is a Partner in the Financial Services Transfer Pricing team with 18 years of tax and transfer pricing experience. Peter has specialised in transfer pricing for financial institutions since 2005 with a particular focus on the investment management sector. This work has ranged from documentation, to audit defence and APAs as well as work on the attribution of profits to permanent establishments. In addition to his time in London, Peter spent 3 years working in the PwC transfer pricing teams in Tokyo and one year with the PwC team in San Francisco on a variety of international transfer pricing projects.

Rex Chan

Tax Partner, PwC Beijing

Qualifications

Member, HKICPA Fellow member, ACCA UK Fellow member, AICPA Certified public accountant, State of Illinois, USA

Professional experience

Rex Chan started his professional career in China tax in Hong Kong since 1991, and then moved to Beijing in January 1998. Rex is PwC’s north China automotive industry tax leader and the engagement tax partner on a number of multinational companies and their China subsidiaries, including: • A few European automakers and their China joint ventures, auto-financing company, trading company and other affiliated entities in China. Rex’s team is retained as the group’s China tax advisor covering transfer pricing, customs, cross-border remittance, permanent establishments, tax accounting and other tax structures related consulting. • Famous Japanese automakers’ China holding company and investees, providing daily operational advice, and most recently a customs/transfer pricing project related to imported vehicles. • A US MNC with multiple business units in various industries, including energy and power, healthcare, transportation and financial services. PwC China has since become the MNC’s China preferred tax service provider under Rex’s leadership. • Another US MNC software company with its core business in database products and servers. Rex has been the engagement partner and the client’s key contact since 2009. Rex’s team has been helping the client in a couple of projects: obtaining turnover tax preferences on sublicensing fees, remittance of intercompany charges, new businesses development and various M&A projects. • Assisted a multinational client in discovering and understanding its multi-layered China taxation exposure of dividend chain; developed strategy and successfully helped the client eliminate the multi-layered taxation. • Identified key business issues for a cosmetic manufacturer client in a dispute with its business partner, helped the client prioritise the issues to be resolved by analysing the relevant implications of various business objectives. • Helped a US client successfully defend its high thin capitalization ratio in a transfer pricing audit, analysed the overall thin cap position by taking into account relevant commercial factors and business objectives, advised the client ways to manage the thin capitalization tax risk.

Sarah Chan

Partner, Tax and Business Advisory Services, Deloitte China

Qualifications

Fellow member, HKICPA Fellow member, ACCA Fellow member, TIHK

Professional involvement

Deputy Chair, Taxation Faculty Executive Committee, HKICPA Member, Taxation Faculty China Tax Sub-Committee, HKICPA

Professional experience

Sarah is a Tax Partner of Deloitte China and has more than 25 years of tax and business advisory experience. She is also the Lead Partner of Business Process Solution team of Deloitte Hong Kong office. Having previously worked in China and the USA, Sarah has extensive experience in advising MNCs on structuring transactions, business reorganization, operational re-modelling, cross-border financing and exploring investment options and exit plans. Her expertise also includes resolving contentious issues and disputes with local tax authorities and managing tax, financial and regulatory reporting of companies with multi-jurisdictions operations. Sarah’s main industry focuses are technology, consumer and industrial products, professional and financial services.

William Chan

Partner, Tax Services, Grant Thornton Hong Kong

Qualifications

Member, HKICPA Fellow member, ICAEW Certified Tax Adviser (Hong Kong) Certified Tax Agent, Qianhai Shenzhen

Professional involvements

Chair, Taxation Faculty Executive Committee, HKICPA Convenor, Taxation Faculty China Tax Sub-committee, HKICPA

Professional experience

William Chan is a partner of tax services at Grant Thornton Hong Kong Limited, a member firm of Grant Thornton International Ltd.

William has over 20 years of experience in providing tax services. Prior to joining Grant Thornton Hong Kong, he worked in Big Four firms in the UK, Hong Kong and Mainland China. William’s expertise focuses on tax due diligence and transaction-related tax advisory work, including pre-deal structuring and post-deal integration tax services. He also specialises in cross-border tax advisory and has extensive experience in advising on suitable investment structures and vehicles for multinational companies investing in Hong Kong and Mainland China, and for PRC companies investing overseas. He has previously stationed in Shanghai for five years and advised on many domestic companies in their onshore and offshore acquisitions.

Lorraine Cheung

Partner, China Tax and Business Advisory Services, EY

Qualifications

Member, HKICPA

Professional involvement

Member, Taxation Faculty China Tax Sub-committee, HKICPA

Professional experience

Lorraine has been with EY for over 20 years. She has had extensive compliance and consulting experiences in China tax and been involved in many investment and re-structuring projects of various industries including trading, technology, imports/exports, computers manufacturing, pharmaceutical and health care, real estate development and many others. Her clients include a number of Fortune 500 companies. The spectrum of her advice spans across inbound investment by foreign companies, domestic tax affairs and controversies resolution. Her specialty also includes international tax planning and cross border structuring.

Eric Chiang

Deputy Director, Advocacy & Practice Development, HKICPA

Qualifications

Fellow member, HKICPA Fellow member, ICAEW

Professional experience

Eric is responsible for managing the Tax Faculty activities of the Institute. His major duties include: • reviewing the proposed new tax legislations in Hong Kong and consolidating comments from the committees and members on the proposed tax legislations in written submissions to the Government; • managing the government relationships in Hong Kong and China on tax matters; • organizing tax seminars and conferences to keep our members abreast on the latest Hong Kong, China and international tax developments; • co-ordinating and taking part in the annual technical exchange meetings with the IRD and the PRC tax authorities; • being the technical editor and an article contributor of the tax related publications of the Institute; and • being the Institute’s representative in the Tax Working Group in the Global Accounting Alliance network.

Doris Chik

Tax Director, National Tax Technical Centre, Deloitte

Qualifications

BBA (Professional Accountancy), Chinese University of Hong Kong MBA, University of Hong Kong Member, HKICPA Fellow member, ACCA Fellow member, TIHK Certified Tax Advisor

Professional experience

Doris Chik is a Tax Director of National Technical Centre and National Learning team of Deloitte in Hong Kong. She has broad professional experience gained from working in different teams, including Business Tax Services and International and M&A Tax Services, technical and training. She also has overseas working experience under a secondment program in the USA. Doris has about 20 years of professional experience in tax services. She specializes in Hong Kong and international tax planning. Doris served many multinational clients, especially in the manufacturing, consumer market, shipping industries and funds. Under her current role, Doris focuses on tax technical analysis, research, tax policy consultation, article writing and internal training. She is a frequent speaker in tax seminars, as well as a writer of tax technical articles and publications.

Jonathan Culver

Partner, International Tax Services, Deloitte

Professional experience

Jonathan is a Financial Services Tax Partner with a Tax Advisory focus. He is a Hong Kong and International Tax specialist, with significant Asia Pacific experience. Jonathan began his career in London where he specialized in complex tax planning. Jonathan has worked both as an advisor and “in-house” and has spent time at US, UK and Australian investment banks. Jonathan specializes in private equity and principal acquisitions; complex financial instruments; structured finance, leasing and Islamic finance; capital markets, booking methodologies and transfer pricing; group restructurings and profit repatriation; tax efficiency and optimization; and tax controversy and disputes. He regularly assists industry bodies in providing technical feedback to the IRD and in responding to OECD consultation documents.

Sandy Fung

Tax Partner, Alternative Investments, KPMG

Qualifications

Bachelor of Professional Accountancy, Chinese University of Hong Kong Bachelor of Law, University of London Member, HKICPA Fellow member, ACCA UK Affiliate, CIOT Member, TIHK Fellow member, ICSA UK Fellow member, ICSA Hong Kong

Professional experience

Sandy is a Tax Partner in KPMG’s Asset Management Group. She has more than 20 years of experience in performing tax advisory and compliance services for financial institutions and MNCs with a particular focus on asset management clients. Sandy was an in-house tax advisor for several global private equity funds. She has substantial experience in implementing the proposed investments, ownership, financing structures and restructuring. She has also been focused on advising the potential tax issues that may arise from the asset management and the exit stages. Sandy provides tax advisory services on investment structures in the Asia Pacific region and cross-border transactions and performs due diligence reviews in connection with M&A transactions. She advises on all aspects of investment structures, including fixed income products, substance requirements, ownership and holding structures, financing arrangements, debt push down strategies and divestment scenarios. Many of the assignments involve the effective use of double tax treaty and consideration of the potential direct, indirect, withholding taxes, capital and stamp duties, etc.

Kasheen Grewal

Director, Deal Advisory, M&A Tax, KPMG

Qualifications

Bachelor of Laws (LLB), Victoria University Bachelor of Commerce and Administration, BCA (Corporate Finance; Accounting), Victoria University Chartered Accountant, CA ANZ Barrister and Solicitor of the High Court of New Zealand (Enrolled)

Professional experience

Kasheen started her career in New Zealand before moving to Hong Kong 7 years ago. Kasheen’s expertise is in large international and regional M&A transactions, including buy-side and sell-side tax due diligence, international tax structuring and post-deal integration. Kasheen mainly works with private equity funds, MNCs, and Hong Kong and PRC-based corporates on cross-border transactions across a range of industries. Kasheen brings in-house commercial experience to KPMG’s M&A tax team having undertaken two client secondments in the telecommunications industry in both New Zealand and Hong Kong, and from working in-house in an M&A and international tax role at Telstra’s international headquarters in Hong Kong for over 3 years. Kasheen brings extensive post-deal and integration experience, having managed the acquisition and international tax integration of a substantial acquisition for Telstra, and brings both regional and international commercial and tax experience from her oversight of international tax matters in Asia and EMEA (Europe, the Middle East and Africa).

Gwenda Ho

Partner, Tax Services, PwC

Qualifications

Member, HKICPA Member, AICPA Member, TIHK Certified Tax Adviser (Hong Kong) Chartered Global Management Accountant

Professional involvements

Member, Taxation Faculty Executive Committee, HKICPA Immediate Past President, AWAHK

Professional experience

Gwenda Ho is a Partner of PwC Hong Kong’s corporate tax practice, leading the technology, media and telecommunications sectors.

She has over 20 years of experience in providing Hong Kong and international tax consulting and compliance services to local, regional and multinational clients. She has been actively involved in a number of tax due diligence, corporate restructuring, cross-border tax advisory, transfer pricing, tax investigations, IPO and blockchain / crypto-related projects. Experienced in advising both overseas MNCs and Chinese companies on investing into Hong Kong as well as using Hong Kong as a platform for outbound investment, Gwenda is also active in the startup community. Besides, she has been actively involved in providing comments on latest tax bills, and is a frequent public speaker on tax-related topics.

Tracy Ho

Partner, Business Tax Services, EY

Qualifications

Fellow Member, ACCA Associate Member, HKICPA

Professional experience

Tracy has been a tax partner of 16 years. She was the Asia Pacific Business Tax Services Leader and the Tax Managing Partner of EY Hong Kong and Macau. As the APAC Tax Leader, Tracy drove the relevant tax services growth across 6 Regions – APAC FSO, ASEAN, Greater China, Japan, Korea and Oceania which covers more than 20 countries in relation to Private Client Services, Tax Policy and Controversy, Quantitative Services and Tax Advisory services enabling to provide insightful, multi-country tax advisory services in a connected and consistent manner throughout every stage of the tax life cycle; planning, accounting, compliance and controversy. Tracy is experienced in providing tax consulting advice for conglomerates which are active in inbound and outbound investments activities, cross border supply chain/distribution models and investment structure. Tracy has substantial experience in dealing with tax authorities both Hong Kong and overseas. Her roles on these significant engagements included direct tax planning, advising on the information possibly requested by and assistance in explaining the business models and transactions in question to the tax authorities. She has been voted as one of the “leading tax advisers” in Hong Kong by the Legal Media Group Guide to the World’s Leading Tax Advisers in each edition since 2007. She regularly contributes articles and presents tax seminars on latest tax development and changes.

Nigel Hobler

Partner, Deal Advisory, M&A Tax, KPMG

Qualifications

Bachelor of Economics, Sydney University Master of Commerce, Sydney University Member, ICAA

Professional experience

Nigel is a partner in KPMG’s Hong Kong Tax practice. He has over twenty years of experience in advising multinational and local clients on tax advisory and compliance matters having worked in Australia, Indonesia and Hong Kong. Nigel has advised MNC and fund groups to establish their operations and assisted with tax due diligence and structuring their investments. This has involved structuring equity, hybrid and distressed debt investments across various industries and sectors, including infrastructure, real estate, agriculture, technology, financial services, telecommunications, manufacturing, consumer and FinTech.

Jane Hui

Partner, International Tax and Transaction Services, HK/China China Tax Technical Leader, EY

Qualifications

Graduate, Chinese University of Hong Kong US Certified Public Accountant

Professional experience

Jane has over 25 years of experience in PRC tax. Besides being an international tax and transaction services partner, Jane is also the technical leader of EY China Tax practice which provides technical and thought leadership support for the entire tax department in China. Jane’s clients include MNCs, local and offshore permanent establishment firms and PRC corporation. Jane has substantial experience in looking at the tax issues associated with transaction targets with PRC operations in various industries including but not limited to real estate, infrastructure, medical, food and beverage (F&B) and financial services.

Jane is familiar with the transaction environment in the PRC and the issues associated with doing deals in China. She has led various engagements on structuring a transactions for both inbound and outbound investments to and from China. Many of these transactions include investing in sizable real estate development projects in multiple locations in China. Jane advises her clients on transaction structure and post-deal restructuring matters; investments in China and other countries in Asia on a regular basis.

Tommy Hui

Senior Manager, Hong Kong Tax Services, PwC

Qualifications

Bachelor of Commerce (Hon), University of Toronto US Certified Public Accountant Member, HKICPA

Professional experience

Tommy Hui is a senior manager in the Tax Practice in Hong Kong with prior experiences in Hong Kong, China and US tax. He has served clients from a wide range of industries where he provided various tax compliance and consulting services. Tommy has been with PwC for more than 10 years advising clients in matters ranging from internal restructuring, amalgamation, divestment, due diligence, etc. Tommy returned from a 2-year secondment in New York within the Industry Service Group where he provided US tax provision and compliance assistance to media and technology companies. Tommy also advised domestic multinationals making inbound investments into the US, including financing and corporate structuring.

Kathy Kun

Director, National Tax Centre, Tax & Business Advisory Services, EY

Qualifications

Fellow member, ACCA

Professional involvements

Examination Panelist, Final Examination of QP program, HKICPA

Professional experience

Kathy is a Director of the National Tax Centre of EY with over 16 years of experience. She has diverse industry experience including real estate, trading, manufacturing and retailing, banking, insurance, financial services and professional services. In her technical role, she is responsible for developing and updating internal tax training materials, as well as conducting internal tax training courses. She is also a frequent speaker at tax seminars, workshops and is one of the authors of EY’s tax client publications.

Winnie Kwan

Senior Manager, International and Transaction Tax Services, EY

Qualifications

Bachelor of Commerce, University of Melbourne Member, CPA Australia

Professional experience

Winnie has over 9 years of experience in providing corporate tax and business advisory services to a wide range of clients including MNCs, listed groups and privately owned businesses. Winnie has clients from various industries, specializing in technology, media, telecommunication. She has been handling tax compliance and tax advisory tasks such as tax due diligence, group restructuring planning, structuring of intellectual property, operation review, offshore claim exercise, advice on cross-border transactions, tax resident certificate applications and permanent establishment assessment for her clients.

Patrick Kwong

Executive Director, Tax & Business Advisory, EY

Qualifications

Bachelor of Business Administration (Hons), Chinese University of Hong Kong Fellow Member, ACCA Associate member, HKICPA Chartered Tax Adviser, TIHK

Professional involvements

Past president, TIHK Advisor, TIHK Member, JLCT Member, Editorial Board, Asia Pacific Journal of Taxation

Professional experience

Patrick Kwong has more than 30 years of tax experience advising clients across various industries and sectors. He is now a tax director and a key member of the technical team of the Hong Kong Tax Practice of EY. He advises clients across various industries and sectors including property development and trading, manufacturing and retail, media and telecommunications, banking and financial services, hotel and service industry and professional services. He is a regular speaker at tax seminars and conferences and has authored a number of tax articles published in various professional journals and magazines.

Cecilia Lee

Partner, Tax Services, Transfer Pricing Services, PwC

Qualifications

US Certified Public Accountant

Professional involvements

Member, Taxation Faculty China Tax Sub-committee, HKICPA

Professional experience

Cecilia has been at PwC for over 20 years, with over 10 years of experience in the United States. She is the head of PwC's transfer pricing practice in Hong Kong and is also the Asia Pacific Champion Partner for PwC's Global Coordinated Documentation service. Cecilia advises clients on various Hong Kong and China transfer pricing issues, including value chain transformation, cost sharing, restructuring, intangible property and audit defence and disputes. Cecilia had been actively involved in the legislation process of the Hong Kong Transfer Pricing legislation. She has successfully assisted in concluding China’s first APA on Cost Sharing Arrangement for a multinational company. She also assisted clients in many planning projects, such as royalty structure planning and implementation. Among other clients, she has successfully assisted in dispute resolution matters with the Chinese Tax Authorities particularly in the area of intangible property transfer and intercompany services. She also advises clients with ongoing transfer pricing disputes with the IRD. Cecilia is a frequent speaker at transfer pricing seminars with clients, professional organizations and tax authorities, and has contributed to professional publications.

Alice Leung

Partner, Corporate Tax Advisory, KPMG

Qualifications

Member, HKICPA

Professional involvements

Chairperson, Taxation Committee, HKGCC Council Member, TIHK

Professional experience

Alice is a partner with KPMG China who specializes in the corporate tax field for over 20 years. Alice has worked with a diverse range of clients belonging to various industries including consumer markets, industrial markets, transportation, telecommunications and media. Alice has extensive experience in advising multinational and local clients on tax compliance and advisory matters. She has helped many clients in applying tax exemption and resolving disputes, tax audits and investigations initiated by tax authorities. She also managed treaty-related services, including obtaining Tax Resident Certificates, applying double-tax relief on transfer pricing adjustments and negotiating APAs. Alice extensively collaborates with many offices in the KPMG network to assist clients optimize the vast growth and opportunities available in the Greater Bay Area. She is also active in advocating KPMG’s and the business community’s positions and views regarding tax policies and reforms to a number of government agencies, professional associations and industry groups. She is a frequent speaker on various key tax issues and developments in both KPMG and external business seminars and conferences. She also contributes articles to business publications.

Ivor Morris

Partner, Corporate Tax Advisory, KPMG

Qualifications

Master Degree in Arts, University of Cambridge Fellow member, ICAEW

Professional experience

Ivor Morris joined KPMG’s Hong Kong office in 2009 and became a tax partner in 2017. Ivor has extensive experience of advising international clients in Hong Kong on their corporate tax matters. He works with a number of shipping and leasing companies advising on their Hong Kong tax matters, as well as many multinational groups on cross-border related matters.

Anthony Pak

Partner, Deal Advisory, M&A Tax, KPMG

Qualifications

Bachelor of Arts (Hons) in Accountancy, City University of Hong Kong Affiliate of Association of Chartered Accountants, United Kingdom

Professional experience

Anthony is a Partner in KPMG’s Deal Advisory and M&A Tax group. He has more than 20 years’ experience in advising multinational and local clients on tax advisory and compliance matters. Anthony has M&A tax experience across the Asia region, and has worked in Shanghai and Beijing for 10 years and 3 years respectively. Anthony has been involved extensively in Hong Kong profits and individual tax compliance and advisory services prior to his move to Shanghai. Subsequent to his move to Shanghai, he has been involved in dealing with cross-border investment into China and advising foreign real estate companies on their investment strategies and structure to comply with various business and tax regulations in China. Anthony has been specialized in M&A from a PRC tax perspective since 2006. He has engaged in various buy-side tax due diligence in wide range of industries, including real estate, machinery, manufacturing, trading and distribution, retail, pharmaceutical, etc. Anthony has provided a wide range of services to his clients including buy-side and sell-side tax due diligence review, tax structuring and post-deal integration, PRC tax compliance and exit support.

Wengee Poon

Partner, Tax Services, Transfer Pricing Services, PwC

Qualifications

Bachelor of Economics and Statistics, University of Rochester Master of Business Administration, University of Rochester

Professional experience

Wengee Poon is a Partner at PwC Hong Kong specialising in Transfer Pricing Services. With extensive experience in transfer pricing, Wengee has resolved transfer pricing matters for numerous MNCs. Her experience includes assisting clients in determining their transfer pricing structures, formulating transfer pricing policies, preparing transfer pricing documentation and performing post implementation structure maintenance services.

Wengee has served a broad spectrum of MNCs in various industries including garments, chemicals, telecommunications, electronics, pharmaceuticals in the manufacturing, distribution and servicing aspects. Wengee is also a speaker at public seminars and has contributed to professional publications.

Murray Sarelius

National Head of People Services, KPMG

Qualifications

Member, HKICPA Chartered Accountant, CA ANZ BBS (Accountancy), Massey University

Professional experience

Murray has more than 20 years of experience with tax issues impacting individuals and businesses operating internationally. Murray advises multinational organisations on matters arising from their mobile workforce, including tax, equity compensation and expatriate policies.

Jennifer Shih

Tax Director, International and M&A Tax Services, Deloitte

Qualifications

Member, CPAC

Professional experience

Jennifer is a Director in the International and M&A Tax Services Group of Deloitte Hong Kong with experience in providing US tax consulting and compliance services to multinational clients. With over 12 years of experience in providing US tax consulting and compliance services to multinational clients, she is well-versed with US inbound tax rules concerning foreign companies doing business and investing in the US. She provides international corporate tax consulting services with respect to US outbound transactions involving controlled foreign corporation (CFC), Passive Foreign Investment Company (PFIC) and etc. She is also experienced in the provision of structuring advice in relation to private equities, hedge funds, and in relation to foreign investment into the US, including investment in US real estates. Jennifer has also been advising a broad range of clients, including foreign financial institutions, with US Qualified Intermediary (QI), FATCA and CRS matters.

Paul Smith

Manager, Corporate Communications, HKICPA

Professional experience

Paul is in the Institute’s Corporate Communications Department. His major duties include: • As editorial manager for A Plus, the Institute’s monthly magazine, setting the editorial direction, writing and editing articles; • producing thought leadership surveys and reports; • preparing the Institute’s annual report; and • preparing and editing the Institute’s communications, publications and other media.

Johnson Tee

Director, Corporate Tax Advisory, KPMG

Qualifications

Bachelor Degree of Business, Monash University Australia Member, CPA Australia

Professional experience

Johnson is a Director of KPMG with 16 years of Hong Kong and Malaysian corporate tax experience, specializing in Financial Services. Johnson has a portfolio of clients in different industries including funds, financial services, trading, manufacturing, etc; and he has been working on corporate tax reporting, advising on transactions, regional compliance matters, M&A and restructuring engagements. Johnson has a wide range of experience in the establishment and structuring of offshore funds, advising on operating protocols for funds, assisting clients on application of tax treaty benefits and advising on the structuring of management fees and carried interest.

Sharon To

Director, International Tax and Transaction Services, EY

Qualifications

Member, HKICPA Chartered Financial Analyst® Certified Tax Adviser Member, TIHK

Professional experience

Sharon has more than 10 years of professional experience in tax and business advisory. She provides tax and business advices to FORTUNE Global 500 companies engaged in different industries including real estates, natural resources, hospitality, electronics, jewelry, and procurement etc. Sharon advises on cross border transactions and structuring such as the inbound and outbound investments in the Asia-pacific region, beneficial ownership, indirect transfer and internal reorganization, etc. She also provides Hong Kong and China tax due diligence services. Sharon is also a core member of EY’s China tax policy team.

Anita Tsang

Director, National Tax Policy Services, PwC

Qualifications

Fellow member, HKICPA Certified Tax Adviser (Hong Kong)

Professional involvements

Member, Tax Sub-committee, ACCA HK Council member, TIHK Vice-President, International Tax Committee, TIHK

Professional experience

Anita has over 15 years of experience in Hong Kong and international taxation. She provided corporate tax and business consulting services to a broad range of local and multinational companies at another big four firm before joining the PwC National Tax Policy Services team. Currently, Anita focuses on providing in-house tax technical support and training at PwC Hong Kong as well as producing the firm’s tax publications. Anita is a regular speaker of professional tax seminars.

Fergus Wong

Director, National Tax Policy Services, PwC

Qualifications

Fellow member, HKICPA Fellow member, ACCA Fellow member, CPA Australia Certified Tax Advisor (Hong Kong)

Professional involvements

Chairman, ACCA HK (2014/15) Member, Global Tax Forum, ACCA Member, ACCA International Council (2013 – 2019) Member, Board of Review of Hong Kong Government, a tax tribunal (for 9 years) Member, Academic Committee, China International Taxation Research Institute (2016)

Professional experience

Fergus Wong is the Tax Director at PwC Hong Kong. He has more than 30 years of experience in Hong Kong taxation including 4 years in the profits tax and salaries tax units of the IRD. He has been involved in assisting client in handling complicated tax disputes cases with the Hong Kong tax authority including cross-border transactions. Having a strong relationship with the government, both the tax policy bureau and the tax administration, he has been able to provide inputs in the tax policy and practice in Hong Kong. He has many years of experience in Hong Kong tax and international tax gained through working in the IRD and as a faculty member of accounting departments of Hong Kong and Australian tertiary institutions. Before joining PwC Hong Kong, he was with another professional firm providing training and in-house technical support. He is a regular contributor to professional journals and has been involved in setting and reviewing taxation examination papers with various professional.

Tiffany Wu

Partner, Tax Services, Transfer Pricing Services, PwC

Qualifications

Bachelor degree in Finance Master degree in Economics Member, HKICPA

Professional experience

Tiffany is a partner at PwC Hong Kong specialising in transfer pricing. She has specialised in providing transfer pricing services in mainland China and Hong Kong. She has been actively assisting clients in transfer pricing planning, reviewing and evaluating transfer pricing risks, rationalising transfer pricing policies, preparing transfer pricing documentation, providing transfer pricing audit defense support and applying APA and Mutual Agreement Procedure (MAP). Tiffany has served a broad spectrum of MNCs in various industries including Fast Moving Consumer Goods (FMCG), electronics, chemicals, telecommunications, IT, etc. She has assisted in concluding the first Cost Sharing Arrangement (CSA) APA in China for a multinational company. She has also assisted in negotiating Bilateral APAs and MAPs and in handling various TP audit defense cases.

Jo-An Yee

Technology, Media, Telecommunications Tax Leader – HK Partner, International Tax & Transaction Tax Services, EY

Qualifications

Fellow Member, HKICPA

Professional involvements

Member, Taxation Faculty Executive Committee, HKICPA

Professional experience

Jo An is a Hong Kong tax partner in EY specialising in the technology and telecommunication areas and has over 20 years of practical experience in providing tax advisory and compliance services clients. She is currently the Technology, Media & Telecommunications Tax Leader for Hong Kong/Macau and principal key contact for Asia Pacific technology sector - tax. Jo An has worked on major telecom and technology accounts and has been actively engaged by well-known companies in their fields on their industry-specific tax issues for digital business such as cloud computing, apps, mobile gaming and online marketplace. Jo An was the co-author of several publications. In particular, besides her involvement with CCH and EY for “The Hands of Guide of Tax Compliance in Hong Kong”, her publications include the thought leadership paper published by EY “Talking tax – Telecom transactions in emerging and mature markets” and “Tax considerations in Cloud Computing”.

Eugene Yeung

Partner, Corporate Tax Advisory, KPMG

Qualifications

Bachelor of Arts (Hons) in Accountancy Bachelor of Laws (Hons) Master of Law and Accounting Fellow member, ICAEW Member, HKICPA Certified Tax Advisor

Professional involvements

Convenor, Taxation Faculty Budget Proposals 2021/22 Sub-committee, HKICPA Member, Taxation Faculty Executive Committee, HKICPA

Professional experience

Eugene is a tax partner of KPMG China. He is based in Hong Kong and experienced in advising on corporate tax issues, deals, tax litigation, regional tax management, etc. Eugene has over 18 years of professional tax experience with a unique mix of exposures. He has spent more than a decade of time with global tax consulting practices in Hong Kong advising local, Chinese and multinational clients on a wide range of corporate tax and company law matters. He has also spent around 5 years with European financial institutions’ Asian tax functions, including a fair amount of time in regional head capacity, leading projects such as setting up tax processes, managing cross-border legal and business restructuring, and handling tax controversies. Eugene is experienced in advising on corporate tax issues, deals, tax litigation, regional tax management, etc. His background and experience enable him to translate complex issues into business implications, and provide pragmatic solutions considering commercial sensitivity. He was named as a leading tax controversy advisor in Hong Kong by International Tax Review and was nominated by Euromoney as a LMG Rising Star.

Patrick Yip

Vice Chair, Deloitte China

Qualifications

MPA Degree in Taxation BBA Degree in Accounting (Hons) LL.M (Master of Laws) Degree, University of California at Berkeley Undergraduate Law Degree (Hons), University of Cambridge MBA Degree (Hons), University of Chicago Senior Executive Program for China, Harvard Business School Member, AICPA Member, HKICPA

Professional experience

Patrick Yip, an experienced international tax partner, is Vice Chair of Deloitte China. He specializes in US international taxation, China-Hong Kong cross-border taxation and structuring M&A transactions. His clients include global and Chinese private equity funds and sovereign funds, and multinational companies in China and the US. He also advises high-net worth individuals on multi-jurisdictional trust and estate planning. In addition, he is a specialist in FATCA and CRS. He was involved in tax policy discussions with both the Hong Kong and Chinese tax authorities. He is fluent in English and Chinese (Cantonese and Mandarin). He won an award in the State of Texas for his CPA exam results. He was named by International Tax Review as a Leading Individual in Tax.

Abbreviation

ACCA Association of Chartered Certified Accountants AICPA American Institute of Certified Public Accountants AIMA Alternative Investment Management Association Limited APA Advanced Pricing Arrangement AustCham Australian Chamber of Commerce AWAHK Association of Women Accountants (Hong Kong) CA ANZ Chartered Accountants Australia & New Zealand CIOT Chartered Institute of Taxation CPAC Chartered Professional Accountants of Canada CRS Common Reporting Standard FATCA Foreign Account Tax Compliance Act FSDC Financial Services Development Council HKGCC Hong Kong General Chamber of Commerce HKICPA Hong Kong Institute of Certified Public Accountants HKVCA Hong Kong Venture Capital and Private Equity Association ICAA Institute of Chartered Accountants in Australia ICAEW Institute of Chartered Accountants in England and Wales ICSA Institute of Chartered Secretaries and Administrators IRD Hong Kong Inland Revenue Department JLCT Joint Liaison Committee on Taxation M&A Mergers and Acquisitions MNC Multinational corporation OECD Organization for Economic Cooperation and Development TIHK Taxation Institute of Hong Kong