On the morning of February 23, 2025, the 94th Lecture of Xiamen University's "Topwe" Advanced Tax Law Practice Lecture Series was held in A304 classroom of the Law School. The lecture was delivered by Ms. Wang Hui, Vice President of Shanghai Huahe Group, and was titled “Top-level Tax Design and Risk Management of Chinese Enterprises' Overseas Investments - A Tax Leadership Perspective”. Mr. Kou Yimin, Partner of Beijing Jingshi Law Firm, Mr. Ye Yongqing and Mr. Lan Meng, Partners of Beijing King & Wood Mallesons Shanghai Branch, Mr. Shi Chu, Tax Manager of ByteDance, Mr. Ai Lijie, Legal Manager of Beijing Jingdong Century Trading Co. Ltd., Wang Xiaohui, Director of Jiangsu Tongtax (Fuzhou) Law Firm and Ge Xilan, Liu Beijia, Taxation and Finance Consultant of China Business Solutions, Wu Qinglun, Senior Practice Expert, Lin Hao, Lawyer of Xiamen Office of Fujian Tuo Wei Law Firm, and Qiu Dongmei, Associate Professor, as well as Master and Doctoral Students of Taxation and Finance Law (including the COTP program) attended the lecture, which was presided over by Cai Qinghui, Associate Professor.

At the beginning of the seminar, Ms. Wang Hui started from three tax cross-border cases, analyzed and illustrated in-depth the challenges and potential worries brought by inefficient tax structures and internal control failures for enterprises to carry out cross-border business, and showed the teachers and students the tax risks and challenges of Chinese enterprises' overseas investment under the “double-cycle” pattern.

Subsequently, on how to design the tax risk system for Chinese enterprises going overseas, Ms. Wang firstly introduced the main tax risk management modules of enterprises based on the COSO model and explained in detail the connotation of the five elements of internal control in the COSO framework: internal environment, risk assessment, control activities, information and communication, and internal supervision. Ms. Wang Hui then showed the tax risk points combing table summarized in the business, so that the students could have a clearer understanding of the tax risks that might be involved in the actual business. In addition, Ms. Wang also explained the possible tax risks involved in the major aspects of Chinese companies' overseas investment in combination with tax treaties.

In addition to the analysis from the tax perspective, Ms. Wang Hui also guided the students to think about the design of tax compliance and risk management system from the organizational perspective. She mentioned that firstly, enterprises need to formulate a unified and clear system and working procedures to respond to the changes in the operation of the enterprise in a timely and flexible manner; secondly, in the context of the increasingly extensive demand for cross-departmental cooperation, enterprises need to establish a clear system of authority and responsibility of personnel, in order to better promote the synergies and cooperation between departments; lastly, enterprises need to set up a series of guides on dealing with tax issues for the business departments, so as to ensure the effectiveness of business operations.

In the third part of the talk, Ms. Wang Hui suggested that tax professionals should possess core tax skills, business acumen, interpersonal skills and leadership skills from the perspective of international talent development. In the face of the current employment environment and fast-changing times, she advised students to focus on the constant and forge competencies that can stand the test of time. At the same time, she also encouraged students to learn to know themselves better, combine their passions, specialties and the trend of the times, actively expand their horizons, develop comprehensive abilities, and build themselves into π-type tax management talents.

During the lecture, the audience actively interacted and participated in the sharing of experience and insights. On the issue of tax structure design mentioned in the lecture, Shi Chu, Ye Yongqing and Kou Yimin shared their understanding of tax structure design based on their practical experience. In response to the issue of tax talent cultivation in the lecture, Muba, master's degree students of COTP program of class 2024, Zhanglu and Chen Dunyang also shared their insights on the growth of their career paths and the correct understanding of themselves in the light of their own experiences.

Finally, Associate Professor Cai Qinghui made a concluding speech and expressed his gratitude to Ms. Wang Hui for her wonderful sharing. The seminar enabled the participants to have a deeper understanding of the tax-related risks of Chinese enterprises' overseas investment and the related tax design and issues, which brought the cutting-edge thinking direction for the practice of finance and tax law, and also guided a clearer direction for the personal growth and career planning of the students present.

(Article/Photos by Liu Yujie)