Next Generation Partners

Tax: foreign firms in China

Baker McKenzie FenXun

‘Thorough, rich and rigorous’ in its approach, Baker McKenzie FenXun works on a range of tax matters in China, from M&A, and transfer pricing, to tax controversies and personal income tax compliance. The firm stands out for its specialist tax group which focuses on the Chinese market. Practice head Brendan Kelly is a highly experienced practitioner who advises multinationals on M&A, and assists them with developing integrated and tax-efficient supply chain structures, as well as in defending against tax audits and assessments. Amy Ling and Nancy Lai provide tax-related services to both international and domestic clients. Frank Pan recently joined the firm from PWC Beijing and the team is praised for its ‘ability to anticipate client needs‘ and its ‘willingness to go above and beyond‘. The practice is lent further support in mainland China by its joint partnership FenXun Partners. Key names there include senior tax counsel Jinghua Liu and tax consultant Abe Zhao.

Practice head(s):

Brendan Kelly

Other key lawyers:

Nancy Lai; Jason Wen; Abe Zhao; Jinghua Liu; Luis Zhang; Amy Ling; Frank Pan


‘I’ve dealt with Baker McKenzie outside of China and as per my previous encounter – it seems ingrained in Baker’s approach to be thorough, rich and rigorous with all matters entrusted to them.’

‘I have found the experience, skills and network of Baker Mckenzie in their professional remit to be deep and informed.’

‘Willingness to go above and beyond. Baker Mckenzie seems to have a “never compromise” quality approach.’

DLA Piper

DLA Piper‘s extensive tax practice advises clients on a wide range of international and domestic tax issues from corporate and individual tax planning to dispute resolution. Its lawyers have extensive experience in M&A tax matters, including post-acquisition integration and supply chain management. They also work on structuring inbound and outbound investment and contractual relationships. Windson Li has almost two decades of experience in Chinese and cross-border tax services. He specialises in combined tax and corporate planning services for foreign investment in China. Tina Xia leads China tax matters from Hong Kong and was appointed Head of China Tax in May 2022. Daniel Chan retired and Doris Ho left the firm.

Practice head(s):

Windson Li; Tina Xia; Anderson Lam (Hong Kong)

Gide Loyrette Nouel A.A.R.P.I.

A ‘great team with a very practical mindset’, Gide Loyrette Nouel A.A.R.P.I. supports both large Chinese industrial organisations and French and other European manufacturers and retailers – notably automobile manufacturer Renault and pharmaceuticals giant Ipsen – with tax structuring and planning for major transactions. The tax team works closely with related practice areas such as corporate and projects to provide a comprehensive and tailored service for its clients. Guo Min specialises in PRC taxation and accounting, and works on M&A, cross-border restructurings and joint venture projects. Significantly, Min is PRC Bar-qualified, meaning she is able to litigate in China. Tax restructuring is a key strength of the practice, making up a large amount of its workload alongside the tax implications of large acquisitions.

Practice head(s):

Guo Min


‘Great team, with a very practical mindset, and able to support on many different areas.’

‘Guo Min is fantastic. Very practical mindset, always available, and has the capacity to support us on very different topics.’

Key clients

Aluminum Corporation Of China



Framatome (Ex-areva Np)







CMS handles cross-border transactions for automotive, machinery and equipment, manufacturing, chemical, life sciences, consumer products, finance and insurance, energy and logistics companies from Europe. Nicolas Zhu works frequently with French speaking clients, having previously worked for a French law firm. Gilbert Shen advises on, among other areas, profit repatriation schemes, investment exit strategies, cross-border transactions and tax due diligence.

Practice head(s):

Nicolas Zhu; Gilbert Shen

K&L Gates

Roberta Chang, based in Shanghai, and Sydney-based global tax practice head Betsy-Ann Howe are key figures in the K&L Gates tax team, supported by associate Anita Zhou. The practice assists clients operating in China, including multinational companies, on cross-border tax issues, such as those pertaining to acquisitions and joint ventures, corporate restructurings, financings, and dissolutions. It also provides advice on tax considerations in administrative law controversies and appeal cases, as well as more general compliance advice.

Practice head(s):

Roberta Chang; Betsy-Ann Howe

Other key lawyers:

Anita Zhou


Grace Lin‘s tax practice at Cuatrecasas provides advice for foreign companies – particularly those from Spain and South America – on their operations in China. She acts on transactions in multiple sectors, including automotive, industrial engineering, chemicals and life sciences.

Practice head(s):

Grace Lin

Key clients


Elay Group

Morchem, S.A.

Doga Gestio

Gorlan Team

Fagor Metal-forming Machine Tool Kunshan

Maier Group

Manusa Gest, S.L.

Heineken España, S.A.

Oncomatryx Biopharma, S.L.

Work highlights

  • Providing tax advice on Iberia’s regular business operations in China, and Iberia headquarters’ transactions involving China.
  • Providing tax advice on Elay Group’s business operation in China, among others, including (i) tax advice for intra-group transactions; (ii) tax advice for the expatriates working in China.
  • Providing tax advice to Morchem on the intended intro-group restructuring.