EY - BorderCrossings: Transfer pricing news about China and India

EY International Tax Webcast

BorderCrossings with EY's transfer pricing and tax professionals

Transfer pricing news about China and India

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Learn the latest transfer pricing news about China and India

As part of its efforts related to the OECD’s Base Erosion and Profit Shifting (BEPS) project, China’s State Administration of Taxation (SAT) plans to finalize Special Tax Adjustment Implementation Measures (STAIM) later this month covering transfer pricing, cost sharing agreements, advance pricing arrangements (APAs), thin capitalization, controlled foreign corporations, and the general anti-avoidance rule. STAIM will significantly affect tax planning, compliance, and controversy resolution for multinational enterprises (MNEs) operating in China.

For MNEs operating in India, transfer pricing challenges continue, but there is good news. Recently, the IRS announced that it will begin accepting US-India bilateral APAs starting 16 February 2016.

Join our EY panels as we discuss what these developments could mean for your business. Our EY China panel will discuss how STAIM could affect your China-related transfer pricing strategies, while our EY India panel will focus on how the IRS announcement could affect the transfer pricing and tax controversy environments in India. Specific topics include:

  • How STAIM’s emphasis on the “service recipient” could change your transfer pricing analysis and documentation
  • Updates on India’s APA program and mutual agreement procedure cases with the US

During this live, interactive webcast, EY transfer pricing professionals will take questions from the audience.

This program will be of interest to vice presidents/directors of tax/international tax/transfer pricing/customs/global trade, directors of finance, CFOs, international tax managers, and tax accountants looking for the latest practical information and guidance to support their global business initiatives. We hope you will be able to join us.

Save the date for the next BorderCrossings webcast: The Latest IRS Restructuring: LB&I 2.0 or LMSB 2.0?

1:00–2:15 p.m. EST New York/Toronto; 10:00–11:15 a.m. PST Los Angeles/Vancouver

  • Thursday, 25 February



Jessica Tien

Ernst & Young LLP (US), International Tax Services

Jessica Tien is a member of Ernst & Young LLP and serves as a principal of International Tax Services, resident in San Francisco. Her primary specialty is Transfer Pricing (TP), particularly experienced in the Technology and Retail sectors. Jessica currently serves as the transfer pricing partner for several of the Firm’s global priority accounts advising companies in intangibles planning, supply chain transformation, transfer pricing risk mitigation, operational transfer pricing, global documentation and global disclosure compliance.

Up to June 2014, Jessica was the TP Leader for the EY member firm practices in Greater China, working and living in Beijing and Shanghai for seven years. In addition to leading the practices in Mainland, Hong Kong and Taiwan, she was the China TP advisor for many EY global priority accounts. Jessica led efforts to conclude bilateral APAs in China with Korea, Japan and the US, and assisted clients with anti-tax avoidance audits across China. She has provided and continues to provide consultation to the State Administration of Taxation as a subject matter resource.

Jessica holds an MBA degree in Finance from the University of Chicago and a BBA degree in Finance from National Taiwan University.

Travis Qiu

Ernst & Young (China) Advisory Ltd., Transfer Pricing and Operating Model Effectiveness

Travis Qiu is a tax partner of Ernst & Young (China) Advisory Ltd. based in Shanghai, focusing on transfer pricing (TP) and operating model effectiveness (OME) services. He has more than 20 years of experience in the international tax area. Travis joined EY in 2005 and has also worked with the tax practice of Ernst & Young LLP in New York. He currently leads the Central China TP practice and is a member of the Greater China Transfer Pricing Leadership Committee. His experience includes advising multinational companies in numerous industries on China investment, OME, business restructuring, TP, etc. He assisted multinational companies in TP audit defense, MAP and BAPA projects, and represented companies in the negotiations with tax authorities to achieve favorable results. He also served as the key advisor in the design and implementation of the tax effective supply chain structure in Asia for a number of MNC companies in the FMCG, chemical and TMT industries. Travis works closely with China’s State Administration of Taxation (SAT) on international taxation matters including serving as the external advisor in various BEPS localization projects driven by the SAT in China.

Travis received a Bachelor (First Class Honours) in Accounting from Victoria University of Wellington in New Zealand and a Bachelor of Economics from Xiamen University in China. He is a member of the China CICPA.

Miller Williams

Ernst & Young LLP (US), US-India Transfer Pricing Leader

E. Miller Williams, Jr. is one of Ernst & Young LLP’s lead Transfer Pricing Controversy Professionals in the United States. Miller consults with multinational corporate clients on a national basis regarding complex transfer pricing matters with an emphasis on international transfer pricing controversy, advanced pricing agreements (APA), competent authority (CA), and intercompany planning and structuring.

As part of Miller’s role, he heads the firm’s US-India bilateral transfer pricing controversy initiative from the US perspective, including CA, APA and other international tax disputes.

Miller received his LLM in Taxation from Emory University, his JD from Stetson University College of Law and his undergraduate degree from Vanderbilt University.

Vijay Iyer

Ernst & Young LLP (India), India Transfer Pricing Leader

Vijay Iyer is a partner with Ernst & Young LLP (India) in New Delhi, India. He is that firm’s National Leader for Transfer Pricing.

Over the past 18 years, Vijay has worked on a wide range of tax and regulatory issues. He has significant experience in advising clients on transfer pricing and international tax, including outbound investment from India to overseas. Vijay also has considerable litigation experience including litigation strategy and litigation support to clients.

Vijay has been rated as one of the World’s Leading Transfer Pricing Advisors for India by the Legal Media Group and by International Tax Review.

Vijay is a member of the Institute of Chartered Accountants of India and has a bachelor’s degree in Commerce, from Delhi University.


Craig Sharon

Ernst & Young LLP (US), Transfer Pricing

Craig Sharon is a member of Ernst & Young LLP’s Transfer Pricing practice. He is based in Washington, DC, but spends considerable time on the west coast.

Craig practices in all aspects of transfer pricing planning, compliance, and controversy and has particularly deep experience with advance pricing agreements (APAs) and competent authority proceedings. Prior to joining Ernst & Young LLP in May 2013, Craig served as the IRS APA director from 2008 to 2011. As APA director, Craig was a member of the senior executive team within the IRS Office of Associate Chief Counsel (International) (ACCI), and in his last year with the IRS, Craig was intimately involved in the development of the restructuring plan that led to the creation of the IRS Large Business & International (LB&I) Division and the merged Advance Pricing Agreement and Mutual Assistance (APMA) Program.

Craig received his BA in Economics from the University of Idaho and his JD from Georgetown University Law Center. He was an adjunct transfer pricing professor in the graduate tax program at Georgetown law from 2006 to 2012. Craig is also a frequent writer and speaker on transfer pricing and related international tax issues.