TSANG Yu Shan, Violet

Violet is Senior Tax Manager of the Firm. Upon graduation from the Hong Kong Polytechnic University, she started her career in taxation services. She has experience of over 10 years and her client portfolio covers listed corporations, multinational enterprises and local firms.

Initially, she engaged in provision of tax advisory and compliance services. She is able to identify crux of issues and to provide feasible advices and solutions. In recent years, she focuses on handling field audit and tax investigation. She is capable of negotiating with Inland Revenue Department (“IRD”) and settling long outstanding tax disputes. The cases she handles involve Hong Kong tax, China tax and international tax.

The cases she settled in recent years include:

• Tax arrangement between a Hong Kong incorporated company and British Virgin Islands incorporated companies, which the IRD challenged that the sole and dominant purpose of tax arrangement was to obtain tax benefits under Section 61A of the Inland Revenue Ordinance (“IRO”), and the years of review covered 18 years;
• Offshore claim of a Hong Kong incorporated company, which the IRD challenged that part of the profits should be arising in or derived from Hong Kong under Section 14 of the IRO, and the years of review covered 25 years;
• Transfer pricing audit of a China incorporated company, which the China State Taxation Administration challenged that the payments made to Hong Kong companies were excessive under Article 47 of the Enterprise Income Tax Law and Article 120 of Enterprise Income Tax Law Implementation Rules, and the years of review cover 4 years.

Professional Certifications and Affiliations

• Member of the Hong Kong Institute of Certified Public Accountants
• Member of the Taxation Institute of Hong Kong