Tax Structuring for Overseas Listings by Chinese Enterprises

ForTran advises Chinese companies on tax-efficient structuring from the earliest stages of overseas IPO planning. Our services include jurisdiction selection, offshore entity structuring, asset spin-offs, employee stock ownership plans (ESOPs), and equity incentive schemes. During post-listing operations, we assist in ensuring compliance with both domestic and foreign tax and financial disclosure requirements. We also assist clients in anticipating and addressing potential tax issues arising during profit distribution phases.

Tax Considerations in Cross-Border M&A

Cross-border M&A transactions are often impacted by divergent tax laws and regulatory frameworks. We conduct pre-transaction due diligence to identify target-specific tax exposures and help design optimal tax structures to manage deal-related risks. Our team assesses the downstream impact of mergers, including latent liabilities triggered by the transaction. Where special tax treatments apply, we assist in preparing filing documentation and verifying the commercial substance of the arrangement. We also advise on international tax developments such as Pillar Two rules and treaty changes that may affect future M&A outcomes.

Tax Advisory for Cross-Border Financial Transactions

For complex cross-border financial arrangements—such as total return swaps, QFLP funds, offshore financing, and digital asset transactions—ForTran provides holistic tax risk assessments. We advise on compliance with CRS (Common Reporting Standard) obligations, identify potential exposure at each stage of the transaction chain, and deliver practical solutions to minimize tax and regulatory risks. Our thought leadership in this space is reflected in our authorship of key industry publications, including the Tax Risk Management Guide for the Financial Sector (LexisNexis) and Compliance Handbook for Derivatives and Taxation (Wolters Kluwer).