Paul Tang

Paul Tang

Partner, PwC China


  • Paul Tang is a partner of Transfer Pricing Services practice at Shanghai office, PwC China. He has more than fifteen years of transfer pricing experience.  Paul has been worked in Shanghai, Hong Kong, Beijing, and Toronto offices of PwC Global Network.

Relevant experience

As one of PwC national transfer pricing core members, Paul assisted clients in successfully concluding China's first Mutual Agreement Procedure (“MAP”) with Japan (corresponding adjustment), two of China's first bilateral advance pricing arrangements (“APAs”) with Europe (Denmark), China’s second BAPA with US, China’s first MAP with Norway (corresponding adjustment), and China’s first bilateral APA with Switzerland.

Paul’s recent highlights in terms of transfer pricing audit defence include:

  • Assisting an MNC in defending its transfer pricing positions in China during a national joint transfer pricing investigation initiated by China’s State Administration of Taxation (“SAT”), and achieving nil adjustment for nine Chinese subsidiaries in different locations.
  • Assisting a global leading high-tech company in an intensive national joint transfer pricing investigation, and achieving nil adjustment for all of the three subsidiaries in Shanghai.
  • Assisting a Europe-based MNC in defending its transfer pricing positions through risk-assessment process conducted by local tax authority in Shanghai, and achieving nil adjustment.

Paul is currently involved in a number of bilateral APA and cross-border corresponding adjustment projects in Beijing, Jiangsu, Shanghai and Tianjin for MNCs from the US and Europe of various industries, as well as state-owned enterprise headquartered in China.

Paul’s major client portfolio includes the companies in the retail and consumer (“R&C”), high technology, and financial services industries.

As a Base Erosion and Profit Shifting (“BEPS”) advisor, Paul is the translator of and responsible for the Chinese version of BEPS Report Action 8-10 (Aligning Transfer Pricing Outcome with Value Creation) and Action 13 (Transfer Pricing Documentation and Country-by-Country Reporting) published by China’s SAT.


  • Paul holds a Bachelor of Law degree from Fudan University as well as the certificate of legal professional qualification.
  • Paul was recognised by Euromoney’s Legal Media Group as the Rising Stars 2015 (Transfer Pricing Attorney, China).



  • Tax Services