On February 22, 2025, the 10th Frontiers of International Tax Law Forum was successfully held by the Center for International Tax Law & Comparative Taxation of Xiamen University (CITACT-XMU) and the Law School of Xiamen University.

With the theme of “Emerging Tax Issues in Cross-Border Investment and Financing within the Landscape of International Tax Reform”, the forum attracted a large number of experts from academia and practice.

The forum started at 9:00 a.m. with a welcome speech by Prof. Yixin Liao, Director of CITACT-XMU. Prof. Liao warmly welcomed the participants and reviewed the teaching relationship established between Prof. Kees van Raad of the Center for International Tax Law of Leiden University and the international tax law team of Law School of Xiamen University since 2004, and expressed his gratitude to Prof. Kees van Raad for his excellent contribution to the field of international tax law, and then presented a commemorative plaque of the "Yixin" lecture to Prof. Kees van Raad. Addtionally,Prof. Liao Yixin pointed out that the new international situation under the background of "Two Pillar" poses challenges to the practitioners of international tax law, and stressed the importance of this seminar for the in-depth analysis of cross-border investment and financing tax issues in the context of the continuous progress of international tax reform.

(Professor Liao Yixin presenting the “Yixin” commemorative plaque to Professor Kees van Raad)

Afterwards, Prof. Kees van Raad, former Director of the Center for International Tax Law at Leiden University in the Netherlands, also delivered a speech, expressing his joy of coming Xiamen University again. The participants then took a group photo, which opened the prelude of this academic event.

The morning lecture by Prof. Kees van Raad focused on “The United Nations and International Tax Law---The 2025 Update of The UN Model and the UN’s International Tax Policy Leadership Aspirations.As a leading expert in the field of international tax law, Prof. Kees van Raad provided insights into how the UN is playing an increasingly important role in global tax governance, particularly in terms of innovations in cross-border tax harmonization and tax fairness. He provided the participants with insights and forward-looking thinking.

In the afternoon, the forum was divided into two sessions, the first session was centered on “Issues in the application of Tax treaty in Cross-border Transactions”, chaired by Prof. Zhu Yansheng, Deputy Director of CITACT-XMU, with five speakers and two disscussants. Among them, Mr. Ye Yongqing, Senior Partner of Beijing King & Wood Mallesons Shanghai Office, shared a case study on tax treatment of EPC project, and discussed how to reasonably deal with the complex tax challenges in the context of tax authorities' requirement to tax the whole income of the project. Mona Lan , Partner of Beijing King & Wood Mallesons Shanghai Office, analyzed the procedural issues in the application process of tax treaties by using the case of beneficial owner . Qiu Dongmei, Associate Professor of Xiamen University Law School, analyzed the Susino case and pointed out that relevant and important factors for Chinese courts to play a more active role in resolving cross-border tax disputes include the continuous improvement of the technology of formulating international tax rules, the amendment of Article 88 of the Taxation Administration Law, and the enhancement of professional training on international taxation.

Yongqing Ye (Partner, Beijing King & Wood Mallesons Shanghai Office)

Mona Lan (Partner, Beijing King & Wood Mallesons Shanghai Office）

Dongmei Qiu (Associate professor, Xiamen University)

Muba (Attorney, Baker & McKenzie) & Tingting Guo (Attorney, Baker & McKenzie）

Subsequently, Ms.Muba and Ms.Guo Tingting from Baker & McKenzie Law Firm provided practical analysis of cross-border tax challenges from the perspective of tax residents to beneficial owners. After the presentation, Ms. Ma Xiaoyu, Partner of Global Law Office Shanghai, and Ms. Jessica Shi (Tax Manager, ByteDance, ITC 14-15), Tax Manager of ByteDance, as the disscusscants of honor, expressed their insights from the perspectives of how the procedural issues in the application of tax treaties can affect the judgment results, and how to accurately understand and interpret the provisions and definitions of the treaties. Meanwhile, during the Q&A part, Dr. Chen Yanzhong, President of Xiamen Maritime Court, also re-emphasized the importance of professional education in international tax law.

Xiaoyu Ma (Partner, Global Law Office)

Jessica Shi (Tax Manager, ByteDance)

On the Forum disscussion

Dr.Yanzhong Chen

The second session focused on Cross-border Tax Issues and Tax Dispute Resolution Mechanisms” and was moderated by Associate Professor Qiu Dongmei of Xiamen University Law School. Prof. Zhu Yansheng introduced the practice of VAT management for cross-border online service transactions in China and raised the issue of how to tax financial products in the context of the newly enacted VAT Law; Mr. Wu Hao, Partner of Lifeng LLP, shared her views on tax planning for family trusts; Ms. Yang Xiaofeng, Consultant of DLA Piper LLP (Beijing Representative Office), analyzed the impact of restructuring costs on the loss of a local entity from the perspective of transfer pricing; Ms. Kou Yimin, Partner of Beijing Jingshi Law Firm, discussed the impact of restructuring costs on the loss of a local entity. Afterwards, Ms. Wang Hui, Vice President of Huahe China Group, and Mr. Moya(Wu Qinglun), senior tax practice expert, expressed their views as disscusscants, while Dr. Zhang Xuebin, Senior Partner of Shenzhen Smart Tax Consulting Co., Ltd. and Mr. Shi Xiaojie, Tax Director of DSM (China) Co., Ltd. exchanged views through Q&A part, which provided new ideas and methods for the resolution of cross-border tax issues and disputes.

Prof. Yansheng ZHU

Ms. Hao Wu

Ms. Xiaofeng Yang

Ms. Yimin Kou

Ms. Hui Wang

Mr.  Moya WU

Ms. Xiaojie Shi

Dr. Xuebin Zhang

Participants have expressed that international tax rules are undergoing reshaping since a century, the digital economy is becoming a key force in reshaping the global economic structure and global competition pattern, and it is crucial to strengthen the cultivation of professional talents in the field of international taxation. The forum not only promoted in-depth exchanges among all sectors, but also provided new ideas and wisdom for China's future tax reform and tax digital transformation. Finally, Associate Professor Qiu Dongmei summarized the forum, which was successfully concluded with warm applause.

The successful organization of this forum has further strengthened academic exchanges and cooperation in the field of international taxation. The participants agreed that with the acceleration of the digital transformation of the global economy, more challenges and opportunities will come to the field of international taxation, and joint efforts from all sectors are needed in the future to promote the development of the global tax order in a fairer and more reasonable direction.

All the participants

(Article by Li Le, Photos by Zhang Lu)