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PRACTICES International Taxation International Tax Dispute Resolution
Our Practice
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Tax Advisory Services
Tax Compliance and Planning Anti-Fraud Services Tax Agency and Attestation Services
Tax Controversy Resolution
Tax Audit Defense and Response Tax Reconsideration and Litigation Tax Enforcement and Compulsory Measures Criminal Tax Defense
International Taxation
Non-Resident Taxation Cross-Border Investment and M&A Transfer Pricing Two-PIllar Framework Outbound Tax Compliance under BRI International Tax Dispute Resolution
Private Wealth Management
Private Wealth Management - Holistic Planning for Family Wealth Protection and Succession Private Wealth Management - Planning of Effective Control over Family-Owned Businesses Private Wealth Management - Tax Planning for Family Businesses and Members Private Wealth Management - Cross-Border Wealth Management Private Wealth Management - Crisis Management for Family Businesses adn Members Private Wealth Management - Dispute Resolution for Family Businesses and Members
Real Estate
Real Estate - Real Estate Tax Planning Real Estate - REITs Real Estate - Infrastructure Projects Real Estate - Land Development and Relocation/Expropriation Matters Real Estate - Real Estate Development and Property Management Real Estate - Real Estate Dispute Resolution
Financing, Investment and M&A
Financing, Investment and M&A - M&A Tax Planning and Structuring Financing, Investment and M&A - Investment and Financing Financing, Investment and M&A - Mergers and Restructuring Financing, Investment and M&A - M&A Dispute Resolution
Bankruptcy and Liquidation
Bankruptcy and Liquidation - Debt Resolution Bankruptcy and Liquidation - Bankruptcy Filing Bankruptcy and Liquidation - Bankruptcy Reorganization Bankruptcy and Liquidation - Company Deregistration and Liquidation Bankruptcy and Liquidation - Commercial Dispute Resolution
Venture Capital and Investment Funds
Venture Capital and Investment Funds - Fund Formation and Fundraising Venture Capital and Investment Funds - Fund Management Venture Capital and Investment Funds - Fund Product Filing and Registration Venture Capital and Investment Funds - Operation, Governance, and Compliance of Private Funds Venture Capital and Investment Funds - Post-investment Matters and Dispute Resolution for Private Funds
Capital Markets
Capital Markets - IPOs Capital Markets - Bond Issuances Capital Markets - Asset Securitization Capital Markets - Futures and Derivatives Capital Markets - Innovative Capital Markets Transactions Capital Markets - Capital Markets Dispute Resolution
Banking, Insurance, and Trusts
Banking, Insurance, and Trusts - Loans and Guarantees Banking, Insurance, and Trusts - Trusts and Asset Management Banking, Insurance, and Trusts - Financial Leasing Banking, Insurance, and Trusts - Gold Trasactions Banking, Insurance, and Trusts - Fintech and Financial Marketing Banking, Insurance, and Trusts - Financial Dispute Resolution
Corporate and Commercial Law
Coporate and Commercial Law - Corporate Equity Structure Corporate and Commercial Law - Contract Management Corporate and Commercial Law - Accounting and Invoice Compliance Control Corporate and Commercial Law - Receivables and Equity Disposal Corporate and Commercial Law - Corporate Legal Counsel Corporate and Commercial Law - Civil and Commercial Dispute Resolution
Customs and Trade
Trade Dispute Resolution Trade Sanctions and Regulations Anti-dumping Anti-subsidy Customs Operations Free Trade Zone Business
Intellectual Property
Intellectual Property Dispute Resolution Intellectual Property Transactions Trade Secrets Copyright Trademarks Patents
Artificial Intelligence
AI-related Disputes Connected Vehicles, IoT Humanoid Products Integrated Circuits Tax Industry Policies
Digital Economy
Digital and Network Disputes Network and Information Security Online Logistics Online Marketing Data Protection and Utilization Data Assets and Compliance
Healthcare and Pharmaceuticals
Medical and Pharmaceutical Disputes Medical Equipment Procurement and Financing Administrative License Application
Employment and Labor Law
HR Compliance and Employment Policies Compensation, Benefits, and Performance Management Equity Incentive Plans Confidentiality and Non-Compete Matters White-Collar Crime Investigations Employment and Labor Disputes
Regulatory Compliance and Government Investigations
Antitrust Unfair Competition Anti-Bribery and Corruption Anti-Money Laundering
Environment, Society and Governance
Natural Resources and Energy Carbon Neutrality and Carbon Peaking Green Finance Philanthropic Finance Charitable Trusts Environmental Taxation and Environmental Penalties
Administrative Reconsideration and Litigation
Administrative Reconsideration and Ligtigation - Administrative Reconsideration Administrative Reconsideration and Ligtigation - Administrative Litigation Administrative Reconsideration and Ligtigation - State Compensation Administrative Reconsideration and Ligtigation - Petitions and Whistleblower Compliants
Criminal Investigation and Defense
Criminal Investigation and Defense - Criminal Investigation Criminal Investigation and Defense - Criminal Defense Criminal Investigation and Defense - Criminal Risk Prevention Criminal Investigation and Defense - Criminal Crisis Management
International Tax Dispute Resolution
International Taxation
International Tax Dispute Resolution

Domestic Jurisdiction

ForTran attorneys have extensive experience representing both Chinese tax authorities and foreign taxpayers in resolving cross-border tax disputes. Our strength lies in bridging legal frameworks and practical negotiation. We effectively present arguments that prompt adjudicators to consider the implications of bilateral and multilateral tax treaties, investment agreements, WTO rules, and regional free trade arrangements. At the same time, we assist foreign clients in understanding the nuances of Chinese tax law and its interaction with international agreements. Our goal is to facilitate resolution—not escalation—by fostering constructive dialogue that leads to mutually acceptable outcomes.

Foreign Jurisdiction

When cross-border tax disputes arise outside of China, ForTran assists clients in swiftly navigating local remedies, including administrative reconsideration and judicial proceedings. We help assess the appropriate and legitimate dispute resolution pathways while supporting clients in raising jurisdictional objections where necessary. Our services include compiling and submitting critical evidence originating in China—such as contracts, financial records, and comparability analyses—and coordinating with Chinese tax authorities to initiate mutual agreement procedures (MAPs) under applicable tax treaties. This integrated approach ensures that our clients’ interests are protected through all available legal mechanisms and treaty-based relief.


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86 2168868177

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