Table of Contents

Section 1 Legal Services on Compliance and Planning of Onshore and Offshore Assets for High-Net-Worth Individuals (1) Compliance Risk Review Services for Offshore Assets (2) Offshore Income Declaration Services (3) Compliance Services for Stock and Incremental Offshore Assets (4) Onshore Asset Compliance Services (5) Legal Services for Planning of Onshore and Offshore Assets

Section 2 Comprehensive Legal Services Combining Company Law and Taxation (1) Litigation Representation and Account Inspection Services for Shareholders’ Right to Information (2) Comprehensive Services for Corporate Capital Reduction (3) Comprehensive Services for Equity Transfer

Section 3 Tax Legal Counsel (1) Retained Tax Legal Counsel for Enterprises/Individuals (2) Family Tax Legal Counsel

Section 4 Tax Compliance Legal Services (1) Corporate Tax Compliance Legal Services (2) Special Legal Services for Tax Due Diligence

Section 5 Special Tax Legal Services (1) Special Tax Services for Corporate Investment and Financing (2) Special Legal Services for Tax Planning of Corporate Merger, Acquisition and Restructuring (3) Tax Arrangements for Equity Investment and Transactions

Section 6 Legal Services for Responding to Tax Inspections

Section 7 Representation in Tax Administrative Procedures (1) Representation in Hearings on Tax Administrative Penalties (2) Representation in Tax Administrative Reconsideration (3) Representation in Tax Administrative Litigation

Section 8 Tax Criminal Legal Services (1) Criminal Defence in Tax-related Criminal Proceedings (2) Representation in Tax-related Criminal Appeals

01

Legal Services on Compliance and Planning of Onshore and Offshore Assets for High-Net-Worth Individuals

Section 1 Legal Services on Compliance and Planning of Onshore and Offshore Assets for High-Net-Worth Individuals

(1) Compliance Risk Review Services for Offshore Assets

1. Accept entrustment from clients, sign Confidentiality Agreements, and collect basic information and tax-related documents of offshore assets;

2. Interpret and explain tax policies;

3. Analyse and demonstrate compliance risks arising from the forms of clients’ offshore assets from perspectives including but not limited to domestic tax laws;

4. Issue a Report on Compliance Risk Review of Offshore Assets.

(2) Offshore Income Declaration Services

1. Accept entrustment from clients and sign Confidentiality Agreements;

2. After tax authorities issue declaration notices to high-net-worth individuals, provide clients with document checklists and collect relevant materials;

3. Interpret relevant domestic tax laws and policies for clients based on declaration matters;

4. Discuss declaration arrangements with clients;

5. File individual income tax declarations on clients’ behalf.

(3) Compliance Services for Stock and Incremental Offshore Assets

1. Accept entrustment from clients and sign Confidentiality Agreements;

2. Collect basic information and tax-related documents of offshore assets;

3. Analyse and demonstrate compliance risks concerning clients’ stock and incremental offshore assets from perspectives including but not limited to domestic tax laws;

4. Issue a Report on Compliance Risk Review of Offshore Assets.

(4) Onshore Asset Compliance Services

1. Accept entrustment from clients, sign Confidentiality Agreements, and collect basic information and tax-related documents of onshore assets;

2. Provide clients with a tax compliance checklist and request clients to submit specific materials and documents in accordance with the checklist;

3. Conduct interviews with connected parties to understand actual workflows and business management systems, identify potential tax risks in business models. If the onshore enterprise has undergone tax investigations, enquire about investigation outcomes, penalties and subsequent improvement measures adopted by the enterprise;

4. Sort out, review and assess the business scope and workflows of the onshore enterprise. Compile existing business scopes and operational procedures, summarise risk points by module and category, and analyse corresponding legal provisions for each risk point;

5. Sort out tax-related clauses in enterprise contracts and formulate internal tax risk control mechanisms;

6. Provide daily tax legal consultation and retain communication records with relevant personnel for future verification;

7. Regularly or irregularly organise tax laws and regulations, and deliver briefings and policy updates to the enterprise based on its actual situation;

8. Conduct regular internal tax law training to improve professional competence of corporate finance staff;

9. Issue an annual tax compliance summary report to summarise problems emerging during compliance implementation, propose follow-up work plans and evaluate implementation effects. Track subsequent improvement measures taken by the enterprise and provide further professional opinions.

(5) Legal Services for Planning of Onshore and Offshore Assets

1. Accept entrustment from clients, sign Confidentiality Agreements, and collect basic information and tax-related documents of onshore assets;

2. Understand clients’ business models, workflows, internal management systems and existing onshore and offshore equity structure arrangements;

3. Identify whether transfer pricing and connected transactions exist;

4. Confirm the tax resident status of clients and their family members;

5. Analyse risks such as the onshore entity being deemed a permanent establishment of an offshore entity and unreasonable transfer pricing;

6. Collect relevant tax policies and industrial policies of target countries or regions for implementation;

7. Issue a Planning Scheme for Onshore and Offshore Assets.

02

Comprehensive Legal Services Combining Company Law and Taxation

Section 2 Comprehensive Legal Services Combining Company Law and Taxation

(1) Litigation Representation and Account Inspection Services for Shareholders’ Right to Information

1. Sign retention contracts and complete relevant entrustment formalities;

2. Prepare preliminary evidence materials and preserve evidence;

3. Collate client requirements, send formal letters to the company upon client consent, conduct preliminary communications and participate in negotiations;

4. Maintain complete work records and working papers. Reach resolution directly with the company if communications progress smoothly; otherwise proceed to litigation;

5. Complete pre-litigation preparations and supplement evidence;

6. Initiate litigation procedures;

7. Conduct account inspection of the target company together with audit institutions appointed by the client (subject to case complexity). Adopt an integrated legal-tax perspective to identify evidence favourable to the client;

8. Put forward follow-up recommendations based on on-site audit results.

(2) Comprehensive Services for Corporate Capital Reduction

1. Communicate with clients to confirm capital reduction requirements;

2. Understand the operating status, financial position and potential tax risks of the company proposing capital reduction, and design capital reduction schemes with lower tax burdens;

3. Draft relevant documents including capital reduction agreements as required;

4. Prepare balance sheets, asset lists and complete public announcement procedures in compliance with legal requirements;

5. Complete change registration with company registration authorities in accordance with legal procedures.

(3) Comprehensive Services for Equity Transfer

1. Understand the operating status, financial position and potential tax risks of the invested enterprise, and design transfer schemes with lower tax burdens;

2. Assist in drafting, revising and reviewing equity transfer agreements and other contractual documents;

3. Participate in commercial negotiations for equity transfer upon clients’ request;

4. Assist clients in preparing materials required for equity transfer and completing formal change procedures;

5. Provide legal consultation on matters related to equity transfer.

03

Tax Legal Counsel

Section 3 Tax Legal Counsel

(1) Retained Tax Legal Counsel for Enterprises/Individuals

1. Interpret and explain tax policies;

2. Provide consultation opinions on legal and tax issues encountered by enterprises or individuals in daily operation and management via telephone, email, formal letters, meetings and other channels;

3. Analyse and verify the compliance of business activities from a tax law perspective upon clients’ request;

4. Review tax-related clauses in commercial contracts signed by enterprises or individuals with external parties;

5. Assist enterprises in establishing tax compliance systems;

6. Deliver 1–2 special practical training sessions on tax law for enterprises or individuals within the service term;

7. Invite enterprises or individuals to attend free practical tax law training and seminars on new tax policies hosted by our team.

(2) Family Tax Legal Counsel

1. Tax Optimisation for Family Members Scope includes but is not limited to organising tax-related due diligence, issuing tax risk analysis reports, formulating tax optimisation schemes and guiding scheme implementation.

2. Tax Optimisation for Family Enterprises Scope includes but is not limited to organising tax-related due diligence, issuing tax risk analysis reports, formulating tax optimisation schemes and guiding scheme rollout.

3. Resolution of Tax-related Administrative or Criminal Liabilities Scope includes but is not limited to tax compliance planning, representation in tax administrative reconsideration and administrative litigation, as well as tax-related criminal defence.

Confidentiality Agreements will be signed upon accepting client entrustment before provision of the above services.

04

Tax Compliance Legal Services

Section 4 Tax Compliance Legal Services

(1) Corporate Tax Compliance Legal Services

1. Accept client entrustment, conduct interviews with corporate management to understand core business models, capital management, applicable tax categories, cash flow, transactions, shareholder dividends, financial risk control and other matters;

2. Provide the enterprise with a tax compliance checklist and require submission of specified materials and documents;

3. Conduct interviews with finance and tax supervisors of the enterprise to understand actual workflows and business management systems, and identify potential tax risks embedded in business operations. If the enterprise has undergone tax investigations, enquire about investigation outcomes, penalties and subsequent improvement measures;

4. Sort out, review and assess the corporate business scope and workflows. Compile existing business scopes and operational procedures, summarise risk points by module and category, and analyse applicable legal provisions for each risk point;

5. Sort out tax-related clauses in corporate contracts and formulate internal tax risk control mechanisms;

6. Provide daily tax legal consultation and maintain communication records with corporate finance staff for future verification;

7. Regularly or irregularly organise tax laws and regulations, and deliver briefings and policy updates to the enterprise based on its actual situation;

8. Conduct regular internal tax law training to improve professional competence of corporate finance staff;

9. Issue an annual tax compliance summary report to summarise problems emerging during compliance implementation, propose follow-up work plans and evaluate implementation effects. Track subsequent improvement measures adopted by the enterprise and provide further professional opinions.

(2) Special Legal Services for Tax Due Diligence

1. Accept client entrustment, sign Confidentiality Agreements, and collect basic information and tax-related documents of the target entity;

2. Verify the business status of the target company through observation, document review, inquiry, verification, recalculation, interviews and other investigation methods;

3. Examine whether internal control systems of the target company are sound and effectively implemented;

4. Investigate the compliance of tax handling in daily production and operation of the target company;

5. Investigate the compliance of tax handling for major economic events of the target company;

6. Issue a Tax Due Diligence Report.

05

Special Tax Legal Services

Section 5 Special Tax Legal Services

(1) Special Tax Services for Corporate Investment and Financing

1. Clarify corporate investment needs and provide tax planning legal services matching overall investment objectives;

2. Analyse and compare tax burdens and tax risks by comprehensively considering investment structure, location, sector and investment method;

3. Deliver specific investment proposals to the enterprise and prompt overall tax burdens and relevant tax risks;

4. Assist enterprises in completing approval or filing procedures with tax authorities after investment plans are confirmed;

5. Assist in drafting tax legal documents required for enjoying preferential tax policies;

6. Assist enterprises in completing relevant tax administrative change procedures.

(2) Special Legal Services for Tax Planning of Corporate Merger, Acquisition and Restructuring

1. Understand the purpose of corporate merger, acquisition and restructuring, define directions for tax planning services and provide tax consultation throughout the restructuring process;

2. Conduct tax due diligence to grasp the target company’s overall tax profile, status of declaration and payment of various taxes, unreasonable tax arrangements, informal tax relief, non-compliant handling of corporate income tax, turnover tax, individual income tax and other taxes, transfer pricing policies without supporting documents, and potential risks of substantial tax fines and surcharges;

3. Calculate tax burdens and carry out tax planning for alternative restructuring approaches including equity acquisition, asset acquisition, corporate merger, corporate division, debt restructuring, equity/asset transfer and non-monetary asset investment, and provide tax recommendations on restructuring methods;

4. Confirm eligibility for special tax treatment for equity acquisition, asset acquisition, merger, division and debt restructuring to reduce restructuring costs;

5. Identify applicable policies such as VAT non-taxation and stamp duty exemption to cut transaction costs;

6. Issue a Tax Consultation Report on Merger, Acquisition and Restructuring;

7. Assist enterprises in implementing restructuring schemes.

(3) Tax Arrangements for Equity Investment and Transactions

1. Conduct preliminary communications, understand parties’ demands and define work scope and objectives;

2. Carry out preliminary tax and legal analysis based on preliminary communications;

3. Sign a Special Legal Service Contract;

4. Prepare document checklists in accordance with client demands and conduct interviews and investigations when necessary;

5. Analyse tax and legal risks embedded in equity investment and transactions based on materials, interviews and investigation results;

6. Issue a Special Tax Legal Opinion and propose investment and transaction schemes;

7. Guide enterprises to implement the schemes.

06

Legal Services for Responding to Tax Inspections

Section 6 Legal Services for Responding to Tax Inspections

1. After tax authorities serve Tax Inspection Notices on the enterprise, provide document checklists and collect relevant materials;

2. Interview corporate management, finance and business personnel to confirm workflows and verify transactions, financial and tax status;

3. Assist the enterprise in analysing tax legal issues arising from tax inspections;

4. Assist the enterprise in collecting and submitting inspection materials requested by tax authorities;

5. Brief corporate management and relevant staff on inspection procedures adopted by tax authorities;

6. Assist the enterprise in communicating with tax authorities regarding tax legal matters involved in inspections;

7. Assist Party A in communications with tax authorities on relevant tax legal issues arising from inspections;

8. Assist the enterprise in preventing legal risks of administrative penalties;

9. Provide consultation services to the enterprise and relevant personnel for mitigating criminal legal risks;

10. Help the enterprise avoid unnecessary economic losses;

11. Provide remedies recommendations for handling decisions and penalty decisions issued by tax authorities.

07

Representation in Tax Administrative Procedures

Section 7 Representation in Tax Administrative Procedures

(1) Representation in Hearings on Tax Administrative Penalties

1. Review the scope of hearings applicable to tax administrative penalties;

2. Confirm competent authorities for tax administrative penalty hearings;

3. Draft Applications for Tax Administrative Penalty Hearings and assist applicants in submitting written hearing applications within 5 days upon service of Notice of Tax Administrative Penalty Matters;

4. Apply for recusal of hearing moderators for tax administrative penalty hearings;

5. Represent clients in hearing procedures, present defences and cross-examine facts alleged and evidence submitted by tax authorities, and adduce evidence to prove that the client’s conduct does not constitute an illegal act;

6. Exercise procedural rights including reviewing evidence, submitting materials, making statements and presenting defences during hearings;

7. Verify hearing transcripts;

8. Receive documents including Notices of Penalty Withdrawal, Tax Inspection Conclusions or Tax Administrative Penalty Decisions;

9. Provide recommendations on subsequent legal remedies if tax authorities confirm illegal acts.

(2) Representation in Tax Administrative Reconsideration

1. Review the scope of tax administrative reconsideration;

2. Confirm competent reconsideration authorities;

3. Draft Applications for Tax Administrative Reconsideration;

4. Communicate with reconsideration authorities, review and copy evidence materials;

5. Apply for suspension of enforcement of specific administrative acts;

6. Apply for hearing-based trial for major and complicated cases;

7. Participate in tax administrative reconsideration hearings;

8. Take part in mediation and settlement for administrative reconsideration cases;

9. Receive Tax Administrative Reconsideration Decisions and review the legality of reconsideration rulings;

10. Provide recommendations on subsequent legal remedies if tax authorities uphold the original administrative act or issue new adverse administrative decisions.

(3) Representation in Tax Administrative Litigation

1. First Instance (1) Review the scope of tax administrative litigation; (2) Confirm competent courts for tax administrative litigation; (3) Collect evidence materials, draft Complaints and file applications for legality review of cited tax normative documents; (4) Apply to courts for evidence collection for materials unavailable to the client; (5) Submit materials for case filing and conduct pre-trial communications with judges; (6) Attend court hearings and submit written representations based on trial developments; (7) Receive Administrative Judgments and Administrative Rulings; (8) Analyse the feasibility and necessity of lodging appeals and provide recommendations on subsequent legal remedies.

2. Second Instance (1) Confirm competent courts for second instance proceedings; (2) Draft Appeals; (3) Collect new evidence; (4) Submit appeal materials and communicate with judges before hearings; (5) Attend court hearings and present oral arguments; (6) Receive legal documents on behalf of clients; (7) Analyse the feasibility and necessity of applying for trial supervision procedures.

08

Tax Criminal Legal Services

Section 8 Tax Criminal Legal Services

(1) Criminal Defence in Tax-related Criminal Proceedings

1. Investigation Stage by Public Security Organs (1) Establish contact with investigation authorities and confirm charges against suspects; (2) Meet criminal suspects to understand case facts; (3) Provide legal advice to suspects and apply for bail pending trial; (4) Submit written opinions to public security organs and conduct communications; (5) File petitions and accusations against illegal acts committed by investigation authorities.

2. Examination and Prosecution Stage (1) Review, excerpt and copy litigation documents and evidence materials with procuratorates; (2) Meet criminal suspects; (3) Investigate and collect evidence materials related to cases; (4) Apply for bail pending trial; (5) Submit defence and representation opinions to procuratorates and clarify the prosecution’s litigation strategy.

3. Court Trial Stage (First Instance and Second Instance) (1) Examine whether the case falls under the jurisdiction of the receiving court; (2) Review, excerpt and copy case materials at people’s courts; (3) Meet defendants, hear their statements and defences, and verify case facts and evidence; (4) Submit written representations to courts, communicate effectively with judges and understand judicial opinions; (5) Brief defendants on trial procedures and inform them of litigation rights, obligations and key points for attention during hearings; (6) Investigate and collect relevant evidence materials in accordance with law where appropriate; (7) Attend court sessions and participate in court investigation and court debate; (8) Submit representations to courts and conduct communications; (9) Obtain written judgments and provide recommendations on the feasibility and necessity of appeals.

(2) Representation in Tax-related Criminal Appeals

Appeal Lodging Stage

(1) Understand basic case information; (2) Listen to appellants’ demands and meet parties concerned; (3) Apply to courts for access to case files; (4) Review case files, organise case facts and evidence materials, and collect new evidence; (5) Draft legal documents, submit appeal materials and file appeals with courts; (6) Conduct communications with courts; (7) Carry out tax appraisal and related work to support new evidence; (8) Receive legal documents.

Retrial Stage

Cases originally tried at first instance shall be reheard in accordance with first instance procedures; cases originally tried at second instance shall be reheard in accordance with second instance procedures. (1) After case acceptance, communicate with presiding judges on disputed facts, evidence and application of law; (2) Read and copy case files; (3) Respond to the case and attend court hearings; (4) Receive legal documents; (5) Provide recommendations on further legal remedies for cases reheard under first instance procedures if parties disagree with rulings.