Cecilia Lee

Cecilia Lee is the transfer pricing leader at PwC Hong Kong and Co-Leader of the Asia Pacific Transfer Pricing network, with over three decades of specialised experience in transfer pricing. She began her career with PwC US Transfer Pricing Practice in 1995, and in 2006 transitioned to the Chinese Mainland and Hong Kong practice, where she continues to advise multinational corporations on complex cross-border tax and transfer pricing matters.

As the Asia Pacific Champion Partner for Global Coordinated Documentation (GCD) and Base Erosion and Profit Shifting (BEPS) related services, Cecilia has led and coordinated numerous global and regional documentation and restructuring initiatives. Her expertise spans transfer pricing strategy, value chain transformation, and intangible asset valuation, with a particular focus on China, Hong Kong, and the broader Asia Pacific region.

Cecilia’s broad expertise and credentials include:

• Successfully assisted in concluding China’s first Advance Pricing Agreement on Cost Sharing Arrangement for a multinational company.
• Successfully assisted in concluding Hong Kong – China’s first Mutual Agreement Procedure, securing relief for affected taxpayers.
• Representing clients in resolving high-stakes transfer pricing disputes with Chinese tax authorities, particularly involving cost sharing, intangible transfers, and intercompany services.
• Advising on transfer pricing disputes with the Hong Kong Inland Revenue Department, including on international dispute resolutions such as Bilateral Advance Pricing Agreement and Mutual Agreement Procedure.
• Assisting in global value chain transformation projects for the development and implementation of tax efficient structures as well as planning strategies projects such as intangible property restructuring.
• Collaborating with customs specialists to resolve transfer pricing-related disputes with customs authorities in China and the United States. 

Cecilia has served clients across a wide spectrum of industries, including: retail & consumer goods, fashion & luxury, real estate, logistics & transportation, hospitality, technology & electronics, healthcare & pharmaceuticals, legal & professional services, consulting & engineering, telecommunications, food & beverage, media & entertainment, education, manufacturing & industrial, automotive, energy & utilities, and packaging & labelling.

Cecilia contributes to thought leadership by frequently delivering keynote presentations at industry seminars and technical forums, engaging with both multinational clients and tax authorities. Her insights have been featured in various professional publications. She has also played an instrumental role in representing the wider business community in dialogue with tax authorities across China, Hong Kong, and Macau and actively contributing to the development of transfer pricing legislation, offering incisive commentary and sharing market-calibrated insights.

Cecilia is a member of Taxation Faculty of the China Tax Support Group under the Hong Kong Institute of Certified Public Accountants (HKICPA).