ForTran advises Chinese and multinational enterprises on the full tax lifecycle of outbound investments, cross-border M&A, and offshore listings. We provide end-to-end structuring and compliance support, from pre-transaction planning to post-deal integration and profit repatriation.

Tax Structuring for Overseas Listings

We assist Chinese enterprises preparing for overseas listings with the tax design of cross-border holding structures, asset spin-offs, employee equity plans, and shareholder incentive schemes. During the operational phase, we ensure that both domestic and offshore entities comply with local tax, financial reporting, and disclosure requirements. Our services also address the tax implications of cross-border dividend distribution, intercompany transactions, and fund flows.

Tax Due Diligence and Structuring in M&A

We conduct comprehensive tax due diligence for cross-border acquisitions, helping clients identify potential liabilities and assess the continuity of target entity tax positions. We design optimal transaction structures tailored to applicable tax treaties and local rules, while also managing downstream tax effects such as depreciation step-ups, indirect transfers, and tax attribute carryovers. When applying for preferential tax treatment (e.g., special tax deferral for restructurings), we ensure documentation completeness, commercial substance, and regulatory filing compliance.

Cross-Border Financial Transactions

Our team is experienced in advising on the tax treatment of international financial instruments and structures—including total return swaps, QFLP funds, offshore financing vehicles, and virtual assets. We help clients identify CRS exposure, permanent establishment risk, and cross-border reporting obligations. Notably, ForTran contributed to key industry references such as the Tax Risk Management Guide for the Financial Sector (LexisNexis) and the Guide to Compliance in Derivatives and Taxation (Wolters Kluwer), reflecting our leadership in this domain.