Tax considerations permeate business operations and major transactions, directly affecting transaction costs, cash flow, contractual liabilities, and regulatory exposure. Our tax practice addresses tax matters at the intersection of tax law, transaction structuring, and dispute resolution procedures. We focus on the substance of each transaction, documentary evidence, and procedural rights, while taking a coordinated approach to civil, administrative, and criminal risks. In doing so, we help clients enhance the certainty and enforceability of their tax arrangements.

Our team has practical experience in corporate tax compliance, tax audits and disputes, customs classification and duties, cross-border investment, and international tax compliance. We integrate tax law analysis into investment transactions, corporate restructurings, equity incentive plans, and wealth planning. Drawing on our capabilities in corporate and commercial law, restructuring and insolvency, white-collar criminal defense and anti-fraud investigations, employment and human resources, matrimonial and family law and wealth succession, and international expansion, we coordinate transaction structuring, dispute resolution, and risk management. Depending on the needs of each engagement, we also work with accountants, tax advisers, and overseas professional advisers to deliver clear, compliant, and readily implementable solutions.

Main service contents：

● Day-to-Day Corporate Tax Compliance
Tax law review of business models, contractual arrangements, transactions and invoicing practices, supply chains, and related-party transactions; tax risk assessments; enhancement of internal policies and procedures; compliance training; and analysis of eligibility for and application of tax incentives.

● Investment, Transactions, Restructuring and Exit
Tax legal due diligence for real estate development and transactions, investments and mergers and acquisitions, equity and asset transactions, corporate restructurings, debt arrangements, bankruptcy and liquidation proceedings, and deregistrations; analysis of transaction structures and restructuring plans; and drafting and review of contractual tax provisions and arrangements for allocating taxes and related costs.

● Tax Audits and Dispute Resolution
Assistance with tax assessments, inspections, and audits; disputes concerning additional tax liabilities, late-payment surcharges, and administrative penalties; communications with tax authorities and representation in written submissions and defenses, hearings, administrative reconsideration proceedings, and administrative litigation; and disputes between transaction parties concerning the contractual allocation of, and indemnification for, taxes and related charges.

● Customs and Import/Export Taxes
Legal analysis of tariff classification, customs valuation, rules of origin, customs duties, import taxes, and bonded operations; and representation in customs audits, administrative investigations, written submissions and defenses, administrative reconsideration proceedings, and administrative litigation.

● Cross-Border Transactions and International Tax
Structuring cross-border investments and transactions; tax law analysis concerning tax residence, tax treaties, permanent establishments, withholding tax, indirect transfers, related-party transactions, and transfer pricing compliance; and compliance advice regarding cross-border payments, the Common Reporting Standard (CRS), and beneficial ownership information reporting.

● Individual Tax and Wealth Planning
Advice on individual income tax, equity transfers, compensation and benefits, and equity incentive plans; and tax law issues arising from family businesses, wealth succession, and domestic and overseas asset planning.

● Tax-Related Criminal Risk
Assessment and urgent management of tax-related criminal risks; coordination between administrative enforcement and criminal proceedings; criminal defense during investigations, prosecutorial review, and trial; and coordinated responses for companies and responsible personnel, including compliance remediation.