Jinghua Liu

Jinghua Liu

Fenxun Partners


Ms. Liu is a partner at the FenXun Beijing office. She focuses on PRC taxation, tax controversy and international tax planning related to investments in China, as well as tax planning for outbound investment by large-scale Chinese enterprises. Ms. Liu has over 17 years’ experience in advising China tax issues. She has extensive experience in handling transfer pricing and other tax audits. She is also experienced in the areas of M&A tax planning, supply chain management, wealth planning, individual income tax, permanent establishment exposure and voluntary disclosure.

Representative Legal Matters

  • Assisted various multinational companies in handling tax audits and controversies.
  • Advised a US safety and security products and solutions company in a major TP audits involving intercompany sales, services and royalties.
  • Advised a major pharmaceutical company on the global spin-off and transfer of its China business.
  • Advised a leading Chinese pharmaceutical company on the most tax-efficient holding structure for a future public listing for the expansion of its business into new markets, including the US, Asia, Africa and Europe.
  • Assisted a Chinese hotel chain group in structuring its global sourcing platform.
  • Advised a leading pharmaceutical company on the transfer of an entire business line in the Greater China area, including the share transfer, the pre-transfer positioning and Notice 698 filing after closing.
  • Advised a Hong Kong pharmaceutical trading company on permanent establishment risk, capital gain tax on the indirect and direct share transfers, valuation of China entities, as well as negotiations with Chinese tax authorities and handling tax audit by tax authorities.
  • Advised various multinational companies on tax-efficient transactional structures in M&A deals involving China and post-acquisition consolidation strategies.
  • Assisted various Chinese state-owned enterprises in designing the most tax-efficient deal structure and holding structure for their outbound investment projects.
  • Advised various technology and manufacturing multinationals on permanent establishment risk and tax exposures regarding their sales to China and services provided in China.

Professional Honors

  • Woman in Tax Leaders in China, International Tax Review 2016-2021
  • Tax Controversy Leader (China) – International Tax Review, Tax Controversy Leaders Guide 2021, 2020, 2019, 2018, 2017, 2016, 2015, 2014, 2013
  • Tax (Rising Star) – Euromoney Asia Women in Business Law Awards 2013
  • "Up-and-coming Individual" (Tax: PRC Law (International Firms), China) – Chambers Asia 2012
  • “Associate to watch” (Tax: PRC Law (International Firms), China) – Chambers Asia 2011


New York, USA (2003)



University of International Business and Economics (Bachelor of Economics) (1995)

University of Toronto Faculty of Law (JD)(2001)

Boston University School of Law (LLM in Taxation)(2004)