International Tax Dispute Resolution-ForTran

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PRACTICES International Taxation International Tax Dispute Resolution

Our Practice

Corporate and Commercial

General Corporate Advisory Contract Management Equity Structuring and Governance Equity Incentive Plans Financial and Tax Compliance Receivables Management and Debt Recovery

Tax Advisory

Tax Structuring and Compliance Fraud Investigation and Compliance Risk Tax Representation and Expert Opinions

Tax Controversy and Dispute Resolution

Tax Audit and Administrative Hearings Tax Reconsideration and Litigation Tax Enforcement and Administrative Remedies Tax and Financial Crime Defense

International Taxation

Non-Resident Taxation Cross-Border Investment and M&A Tax Planning Transfer Pricing Pillar One & Two Services Outbound Tax Compliance under BRI International Tax Dispute Resolution

Real Estate

Land Development and Urban Renewal Construction and Engineering Infrastructure Projects REITs and Pre-REITs Real Estate Tax Structuring Real Estate Transactions, Operations and Exit

Private Wealth Management

Family Wealth Planning and Succession Family Business Control and Governance Tax Compliance for Family Businesses and Members Cross-border Wealth Management Crisis Management for Families and Family Businesses

Investment, Financing and M&A

Investment and Financing M&A and Corporate Restructuring Tax Structuring for M&A M&A Dispute Resolution

Restructuring and Insolvency

Debt Risk Management Bankruptcy Filing and Proceedings Restructuring Voluntary Liquidation and Corporate Exit Dispute Resolution in Insolvency Proceedings

Venture Capital and Private Equity Funds

Fund Formation and Fundraising Fund Manager Registration and Compliance Fund Filing and Registration with AMAC Fund Governance, Operation, and Compliance Post-Investment Management and Dispute Resolution

Capital Markets

Equity Capital Markets (ECM) Debt Capital Markets (DCM) Securitization and Structured Finance Derivatives and Structured Products Innovative Capital Markets Solutions Securities Litigation and Enforcement

Banking, Finance and Financial Services

Lending and Security Trusts and Asset Management Leasing and Asset Finance Gold-Linked Financial Transactions FinTech and Digital Financial Services Financial Dispute Resolution

International Trade and Customs

Legal Services in Pilot Free Trade Zones (FTZs) Customs Compliance Countervailing Duties (CVD) Investigations Anti-Dumping Investigations Sanctions and Export Compliance Trade Dispute Resolution

Intellectual Property

Patents Trademarks Copyright Trade Secrets IP Transactions IP Dispute Resolution

Employment and Labor Law

Employment Compliance and HR Policy Advisory Compensation, Benefits, and Performance Management Trade Secret Protection and Non-Compete Matters Workplace Investigations and White-Collar Misconduct Labor and Employment Disputes

Civil and Commercial Dispute Resolution

Commercial Disputes Family and Inheritance Disputes Traffic Accidents and Personal Injury Cross-Border Disputes and International Arbitration Enforcement Proceedings and Asset Recovery

Criminal Investigations and Defense

Criminal Risk Prevention and Compliance Crisis Management in Criminal Matters Criminal Investigations Criminal Defense

Administrative Disputes and Remedies

Administrative Reconsideration Administrative Litigation State Compensation Claims Complaints and Whistleblowing in Administrative Matters

Healthcare and Life Sciences

Regulatory Approvals and Market Access Medical Equipment Procurement and Financing Healthcare and Pharmaceutical Disputes

Artificial Intelligence

Tax Incentives and Policy Advisory Semiconductor and Chip Industry Legal Support Humanoid and Bionic Systems Connected Vehicles and IoT AI Dispute Resolution

Digital Economy

Data Assets and Compliance Data Protection and Utilization Digital Marketing Compliance Digital Logistics and Platform Operations Cybersecurity and Information Governance Digital and Online Dispute Resolution

Regulatory and Compliance

Antitrust and Competition Anti-Corruption and Bribery Compliance Anti-Money Laundering (AML) Compliance

Environment, Society and Governance

Natural Resources and Energy Carbon Neutrality and Emissions Management Green and Sustainable Finance Philanthropy, Charitable Trusts & Foundations Environmental Taxation and Enforcement

International Taxation

International Tax Dispute Resolution

Domestic Jurisdiction Disputes

ForTran lawyers act in complex treaty-related tax disputes involving both Chinese tax authorities and overseas taxpayers. We are experienced in presenting cases that require careful coordination between domestic tax rules and international instruments—including bilateral and multilateral tax treaties, investment agreements, WTO rules, and regional trade frameworks. We support foreign clients in navigating how these global instruments are applied in practice by Chinese authorities. Our approach emphasizes resolution over confrontation, aiming to protect clients’ long-term business continuity in China.

Foreign Jurisdiction Disputes

In foreign tax disputes, early-stage strategic guidance is essential. We assist Chinese enterprises in identifying appropriate local remedies—such as administrative appeals, litigation, or negotiated settlements—and advise on raising jurisdictional objections when applicable. Our lawyers coordinate the preparation of Chinese-side evidence, including transaction documents, financial statements, and transfer pricing files, and work with Chinese tax authorities when mutual agreement procedures or information exchange are required. We also support clients in initiating treaty-based consultations to resolve cross-border conflicts and preserve access to treaty benefits.

Contacts

Ryan Yan

Partner

Tel:+86 21 68868177

Email:ryan.yan@fortrantax.com
ryan.yan@cpalawyer.cn

Language:Mandarin,English

Jolene Zhou

Partner

Tel:+86 21 68868177

Email:jolene.zhou@cpalawyer.cn

Language:Mandarin,English

Lily Gu

Legal Assistant

Tel:+86 2168868177

Email:lily.gu@cpalawyer.cn

Language:Mandarin, English

Insights

April,30 2024

Case Analysis: Whether the international freight forwarding services provided by an overseas company entirely outside of China constitute a taxable event for VAT purpose?

Company A commissioned an overseas company B to provide an international freight forwarding service that was carried out entirely abroad. Company A paid B for the service but did not withhold VAT and associated surtaxes. The competent tax authority believes that Company A’s failure to withhold VAT and its associated surtaxes violates relevant tax laws.

15th Floor, Binjiang Vanke Center, 118 Minsheng Rd, Pudong New Area, Shanghai, China, 200135

86 2168868177

info@fortrantax.com

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