Andy Sun

Mr. Andy Sun is the managing tax partner of PwC Hefei office. With over 19 years of experience in providing tax controversy advice and service (“TCS”) to both international and Chinese clients, he has led a wide range of projects across China, covering cities and provinces including Shanghai, Jiangsu, Anhui, Zhejiang, Jiangxi, etc..

Currently, Mr. Sun devotes himself in providing tax controversy advice, domestic or overseas listing structure analysis and implementation support, overall tax planning and tax function analysis for major enterprise groups, financial rebate application for corporate investment and establishment, tax and operational compliance review and advice, investment policy update, merger support, Forex management and operational consultation; he also offers customised investment structure advice, reorganisation arrangements, and operation models for group companies. As a core member of PwC China Central TCS team, Mr. Sun actively leads in a large number of projects in coordination and negotiation with tax authorities across the country.

Specialisation

• Tax support in corporate listings (e.g. clear up historical tax-related issues, design listing structure, apply for tax clearance certificates, etc.)
• Application assistance in financial rebate and industry encouragement funds
• Support in the record filing of Tax treaty benefits
• Coordination of controversies on specific tax matters (taxes in the real estate transfer process, such as land value-added tax planning negotiations, value-added tax invoice issues)
• Tax-related administrative reconsideration and hearing

Recent Achievements

• Served a Hong Kong-based real estate group, analysed and designed for multiple mergers and acquisitions, exits, and joint ventures; negotiated with tax authorities and reached tax exemption arrangements, involving a total tax amount of RMB 6 billion (year 2020, 2019 and 2017);
• Served a Germany-based automobile group, negotiated with tax authorities for its domestic dividends to enjoy treaty benefits, and set a precedent for the dual partnership structure to enjoy Sino-German treaty benefits, involving a total tax amount of up to RMB 150 million (year 2020);
• Served a wearable device manufacturing group company based in Anhui (US listed), communicated with tax authorities on the exit of its VIE shareholders and obtained tax exemption arrangement, involving a total tax amount of RMB 200 million (year 2020);
• Served several Chinese private enterprise groups in IPO preparation, communicated with tax authorities on the exit of shareholders from their holding platforms, and obtained tax exemption arrangements, involving a total tax amount of RMB 350 million (year 2020, 2019);
• Served a Singapore-based industrial group, analysed and designed its Greater China restructuring plan (involving over 100 entities), negotiated with tax authorities, and obtained tax exemption arrangements, involving a total tax amount of up to RMB 4 billion (year 2019);
• Served a number of Chinese online education private enterprise groups, analysed and designed the industrial chain layout of the Greater China region, and negotiated with the government and tax authorities to ultimately keep the original support (e.g. establish business substance in Khorgos) or obtain larger financial support (e.g. in Zhoushan, Meishan, Ganzhou, etc.), involving a total tax amount of up to RMB 70 million RMB per year (year 2019);
• Served a private machinery manufacturing group headquartered in Jiangsu, conducted analysis and design on its backdoor listing, and negotiated with tax authorities to eventually obtain tax exemption arrangements, involving a tax amount of up to RMB 3.5 billion (year 2019);
• Served a private auto parts manufacturing group headquartered in Zhejiang Province, conducted analysis and design for its reorganisation in Greater China region (involving more than 60 companies), and negotiated with tax authorities, to eventually obtain tax exemption arrangements, involving a tax amount up to RMB 2 billion (year 2019);
• Served a number of US-based industry leaders (in beverages, coffee, fast food, etc.) and HK-based real estate groups, conducted analysis and designed exit plans from the Greater China region, and negotiated with tax authorities from more than 60 provinces to perform compliance obligations, involving a tax amount of over RMB 5 billion RMB (year 2019, 2018 and 2017);
• Served a Shanghai-based internet group company (US listed), supported in the negotiation during the national joint investigation conducted by STA, and successfully reduced the settlement amount from RMB 600 million to RMB 6 million (year 2019);
• Served a HK-based real estate group, negotiated with tax authorities for its domestic dividends to enjoy treaty benefits, and set a precedent for the dual BVI structure to enjoy China-Hong Kong treaty benefits, involving a total tax amount of up to RMB 60 million (year 2018).