Xiaoyue Wang

Xiaoyue Wang

Transfer Pricing Practice Leader

KPMG in China

Wang joined KPMG China in 2016. Prior to it, Wang had a long and distinguished career at the State Taxation Administration (STA) of China, rising to the position of Deputy Director General of the International Taxation Department.

Wang was the top transfer pricing official at the SAT for many years. She represented the Chinese government in international negotiations on tax policy and administration. She led the development, drafting and implementation of all major transfer pricing, APA, and anti-avoidance initiatives, both in terms of legislation and tax administration.  She negotiated and concluded over 100 bilateral APAs and MAP agreements between China and other tax jurisdictions, and reviewed each year around 200 TP audit cases.

Wang is a member of the Transfer Pricing Subcommittee of the Committee of Experts in International Cooperation in Tax Matters of the United Nations, and served as a member of the above UN Committee and as an Executive Committee Member of the International Fiscal Association (IFA).

Since joining KPMG, Wang has led over 60 large transfer pricing engagement, including bilateral APAs, MAPs, TP defense, BEPS documentation and global value chain restructuring, etc. Her work has involved companies all over the globe and in a wide range of industries including electronics, automobile, finance, consumer goods, telecommunication, real estate, pharmaceutical, and luxury fashion industries.

Wang is a trusted advisor to clients, with the trust and respect of her former colleagues in government.  Through her many years of government service as the top transfer pricing person at the SAT responsible for crafting and implementing transfer pricing legislation and administration, Wang accumulated deep insight into transfer pricing and tax legislation procedures, and can explain the intentions behind policies, regulations, and practices.

Wang is familiar with the position and expectations of the SAT. While at the SAT, she reviewed each year about 200 TP audit cases and led the negotiation of most bilateral APA and TP related MAP cases. She understands how to prepare a high quality application package that meets the requirements of the in-charge tax authority. Because of Wang’s insight and knowledge, she has helped many clients to accelerate the APA, MAP, and audit defense negotiation processes.

Wang has a favourable and trustworthy relationship with persons at the SAT, the local tax bureaus, and the competent authorities in foreign countries. Such trust and mutual understanding are valuable assets that have allowed Wang to facilitate negotiations on behalf of many clients at KPMG. 

Education and qualifications
  • Ph.D. in Economics, Renmin University, China

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