Sam Mao

Sam Mao joined PwC China in 2009 and has over 16 years of experience in the Transfer Pricing team, working in both the Shanghai and Shenzhen offices. 

Sam is China Tax TMT leader, specialised in the e-commerce, platform and gaming sectors. He is responsible for coordinating TMT clients’ tax planning, transfer pricing, and local compliance related matters among global network.

• He has participated in projects including the design of global value chain optimisation schemes, transfer pricing risk assessments, transaction price adjustments, investigation defenses, and negotiations for advance pricing arrangements. The relevant experience includes: Assisted two multinational corporations (MNCs) in defending their transfer pricing positions in China during national joint transfer pricing investigations initiated by the State Taxation Administration (STA), and has achieved desirable results by reducing tax exposure over one billion for Chinese subsidiaries in different locations. 
• After settlement of national joint investigations, he is currently focusing on subsequent Mutual Agreement Procedure (MAP) and Bilateral Advance Pricing Agreement (BAPA) application with the competent authorities to eliminate double taxation and achieve certainty.
• Led pre-IPO and post-deal advisory projects for MNCs and Chinese domestic companies to design, optimise and implement effective and efficient tax structure and transaction flow.
• Collaborated with the STA to draft the first version of “China APA annual report” in 2010; assisted Beijing Municipal Tax Authority to draft “Transfer pricing risk assessment handbook” for State Owned Enterprises in 2012; and the “Cost sharing arrangement research report” in 2022.

Sam holds a Bachelor degree in Law from Shanghai International Studies University and is certified as a legal professional (People Republic of China Bar).