Practice area

World TP Reviews

Transfer pricing
Baker McKenzie

Brendan Kelly leads transfer pricing practice at Baker McKenzie. He provides transfer pricing planning and audit services. The team is comprised of more than 30 practitioners based in Beijing, Hong Kong and Shanghai. Its services cover transfer pricing risk assessments, APAs, pricing models and negotiations with the local authorities. In addition, the team also takes advantages of its global network in order to provide a more comprehensive service.  

Client feedback 

“Baker McKenzie has provided us excellent support and advice in our TP matter. We actually started out using one of the Big Four firms and, after really bad advice and support from the Big Four firm, we had to bring in Baker McKenzie to help fix some key issues and communications with the tax authorities. They are excellent with audit defence strategy and also in both verbal and written communication (in both English and Chinese). Their written protest responses are excellent and the quality was definitely well above what was provided by the Big Four firm we were using. They also take a taxpayer advocacy approach and don't just roll over/defer to China tax authorities (unlike Big Four firms we have used). Although pricey, they provide value that exceeds the price and I highly trust their advice and support. Our audit defence/strategy has gone much better under Baker McKenzie's lead.” 


Lian Tang He leads transfer pricing practice at Deloitte. It provides a wide range of services such as transfer pricing documentation and advisory, APAs and MAPs and risk management. The team also provides digital solutions, including transfer pricing and CbCR data analytics. 

The team assisted a LED-manufacturing firm in dealing with 10 years of transfer pricing adjustment. It also helped a client on business model optimisation. In this case, both cross-border transfer pricing policies and intra-China transfer pricing policies were considered by the Deloitte China team. 

DLA Piper

Windson Li leads transfer pricing practice at firm, along with Daniel Chen, Peng Tao and Doris Ho. Its professionals include lawyers, economists, certified accountants and tax advisers. The team works closely with its US and European tax team to help clients dealing with transfer pricing challenges and opportunities in both domestic and cross-border transactions. 

The team is engaged in BEPS Action development around the world. It has the capability in offering global transfer pricing services and solutions for adapting to BEPS Action Plan requirements. 

Emma Yang joined the firm as an associate in 2018. Cici Ouyang joined the firm as a registered foreign lawyer in 2019. 

Client feedback 

“Strong technical advices; provided practical solutions; very excellent” 


Cheng Chi leads the transfer pricing practice at firm. It provides services including APAs, MAPs, value chain and business restructuring transfer pricing planning and analyses. The team works closely with the tax authorities and the customs authorities in trying to set up mechanisms to alleviate double taxation. It also offers documentation and BEPS compliance regarding BEPS implementation and policy measures. 

In 2018, the team helped a Chinese real estate group by designing value chain structure, transaction model and pricing policy. It also assisted a Chinese outbound MNE with a China-India MAP to resolve tax disputes in India and avoid double taxation. 

Shirley Li and Michelle Sun joined the firm in 2019.