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The Latest development in regulatory and tax rules and how M&A transactions in China would be impacted by these rules

By John Cu, Paul Ma, Chris Mak and Yvette Chan, KPMG China

Sultana L. Bennett, Competition Law Officer Tel: 416–973–2212E-mail: sultana.bennettsdcb-bc.gc.ca

Canadian Competition Bureau Place du Portage, 50 Victoria Street Hull, Québec K1 A 0C9Canada Website: www.competitionbureau.gc.ca

In 2014, according to statistics from Deatogic, following the upward trend in prior years, inbound Mergers & Acquisitions (M&A) activities showed a downward trend, with the total vaLue of inbound M&A deals down 291 percent year-on-year to US$26,7 billion, and the number of deals down 23,7 percent year-on-year to 447. Foreign Direct Investment (F1011 in the real. estate sector was the single most important contributor to the decline in the overall inbound M&A deal. value, which felt from US$8,36 billion in 2013 to US$4.31 billion in 2014. Finance and consumer goods sectors FDI also registered significant decrease in inbound M&A deal value H 2014. At the same time, the total vaLue of outbound M&A deals is also down by 3 percent year-on year to US$62,9 billion, but the number of deals rose 8.7 percent year-on-year to 388. As China shifts the emphasis of its economic growth model from ‘quantity growth’ to ‘duality development’, Chinese companies are investing in new sectors beyond resource extraction. These sectors include high technology, agriculture and food, real. estate, and services. With deals being done in more sectors, it is not surprising to see that Chinese companies’ investment destinations are also changing: from resource-rich developing countries to developed countries that provide access to advanced technologies, established brands, extensive industry experience and worldwide distribution networks. Earlier this year on 19 January 2015, the Ministry of Commerce (MOFCOM) released the Draft Foreign Investment Law (the Draft Fl Law) which is to con-scaidate and replace three existing taws on foreign investment enterprise, Chinese-foreign ContractuaL Joint Ventures ICLiVs] and Chinese-foreign Equity Joint Ventures lEiVs1 The new draft Law once passed [as further discussed below) will likely have a significant impact on China FDI as it will give foreign investors easier access to the Chinese market.

On the tax front, the State Administration of Taxation (SAT] of the People’s Republic of China (PPG) con-tinues to strengthen the tax collection and adminis-tration of cross-border transactions, and target tax avoidance transactions including M&A transactions and cross-border payments to related parties. This approach has been reflected with the issuance of a number of new tax rules including the revised General. Anti-Avoidance Rules (GAAR) administrative measures (AAR Measures), the revised rubs gov-erning offshore indirect transfers of Chinese assets [Announcement 7, which replaces the previous Guoshuihan 12009] No. 698 (Circular 698)]. the SAT announcement regarding certain Corporate Income Tax (CIT) matters on outbound payments to overseas related parties [Announcement 161, as welt as the number of enforcement cases on tax avoidance, including treaty relief claims and offshore indirect transfers of Chinese assets.

On the other hand, various regulatory policies have been introduced in 2014 and early 2015 to facilitate cross-border investments. Specificatly, restructur-ing transactions and investment with non-mone-tary assets have been facilitated by improvements to tax Rites, and the establishment of more free trade zones points to a greater liberalization of the Chinese investment approval and foreign exchange control regime generally in future years.

China’s inbound M&A deal value and number of deals 2009-2014

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FinancialBrouchure.indd 30 04/05/2017 12:42

China’s overseas M&A deals by value 2010-2014

Draft fi Law anD its impact to inbounD m&a transactionsUnder the current Fl taws, most new foreign investments need approval from Chinese authorities, which can be a complex and time-consuming process. The Draft Fl Law plans to make a significant improvement to current foreign investment approval regime by introducing the “negative list” management method that requires projects only on the “negative list” to go through the approval procedure; white projects that are not on the “negative list- only need to be filed with the Chinese authorities in charge of foreign investment without prior approval. In addition, foreign companies will receive national treatment under the new regulations, a measure that can help create a Level playing field for foreign investors entering China markets.

Another significant change introduced under the Draft Fl Law is that the status of foreign invested companies will not be judged merely on legal ownership but on who is in control.”, that is, foreign enterprises in the mainland which are controlled by overseas investors will be considered -foreign”; while those controlled by Chinese investors will be considered “domestic”. As a result, it will likely be more difficult for the use of Variable Interest Entities (VIE) structures to operate in, and gain benefits from, China companies in the “restricted industries’ or otherwise on the “negative List” if the offshore investor owns a minority stake but exercises de facto real control over the business in China. Given this, it would be interesting to see how offshore Listings of Chinese businesses using VIE structures will be impacted by the Draft Fl Law, and how the China Securities Regulatory Commission (C RC), which is in charge of both onshore and offshore listing, wiLL enforce the new Law on the offshore Listings of VIE structures.

That being said, it is noted that legislation or revisions to Legislation involving foreign investment may take some time, and so the final Fl Law may only be issued in a few years time.

Development of the free trade zones (FTZ)

Following the establishment of the pilot FTZ in Shanghai in September 2013, other FTZs in Tianjin, Guangdong province and Fujian province were formality established on 21 April 2015. Each of these four established FTZs have slightly different areas of focus on reform and policy developments.

From a China M&A perspective, the new FTZs present interesting potent al. The innovations in investment approvaL and administrative

procedures herald a better investment environment for foreigners going forward.

Tax development

Against the relativeLy positive development on the regulatory front, the development on tax front is somewhat concerning, with tax authorities clearly stepping up efforts to combat tax avoidance in tine with the gLobaL initiatives. Further, VAT reform could also create unintended cost consequences for certain businesses and such changes and impacts will need to be carefully evaluated and assessed in M&A transactions.

Recent developments with the Chinese indirect offshore disposal tax rules

On 3 February 2015, the SAT finally issued the Long-awaited Announcement 7 on issues relating to CIT on gains from indirect transfers of Chinese assets by non-resident enterprises. Announcement 7, together with its supplementary circular, Shuizonghan [2015] Nor 68 (“Circular 681 issued on 13 May 2015, have introduced severaL positive changes to the rules set out in the ‘old’ Circular 698, including:i) Strengthening the focus on the -business purpose” of an arrangement when considering whether or not a particular arrangement should be treated as a tax-avoidance transaction; this is consistent with the approach in the GAAR Measures:ii) Introducing “exclusions” from the application of Announcement 7 (specifically, purchase and sale of a Listed company on the public market, and indirect transfer where a treaty exemption would otherwise be available for a direct transfer of the underlying taxable assets):iii) Introducing a -safe harbour- for internal or intra-group restructurings which satisfy the specified conditions, including meeting certain minimum threshold requirements between the transferor and transferee and the requirement that the transfer consideration must be entirety in the form of equity:iv) Requiring local tax authorities to provide a written acknowledgement receipt on receipt of reporting under Announcement 7; and v) Introducing detailed procedures for case establishment and adjudication, as viten as requiring the SAT’s endorsement for actions and determinations by investigating Local tax authorities; this would provide procedural. protections to taxpayers and should prevent local tax authorities from arbitrarily raising tax assessments.

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This new guidance should help enhance the consistent application of the new rules to indirect transfer transactions and vvoutd be welcome by the investment community.

Notwithstanding the above, there are also severat new provisions in Announcement 7 which could potentially create adverse impact for offshore investors involving M&A transactions, including both buyers and sellers. Specifically, these include: i) Expansion of the scope of indirect transfers which would be caught under Announcement 7 to capture offshore transfer of equity or other similar ‘equity-Like) interests in the foreign resident enterprise which results in the same or similar transactional. outcome as a direct transfer of the Chinese taxable assets; ii) Introduction of a ‘deeming provision’ under which an offshore indirect transfer would ‘automatically’ be regarded as Lacking ‘reasonable business purposes’ , and as such subject to PRC tax, if the specified negative criteria are all satisfied (deeming provision); iii) Introduction of withholding obligation and penalty on the buyer: and iv) Introduction of potential penalty/ interest that could be levied on buyer/ seller for the non-compliance of the tax reporting and payment/ withholding obligations.

Under the ‘deeming provision’, it would now be difficult for the offshore seller to assert the position that the disposal of a pure offshore special purpose vehicle which owns Chinese taxable assets only should not be subject to PRO tax, given that such a structure would now be deemed to tack ‘reasonable business purposes’ where it failed to meet the test prescribed in the specific guidance issued.

As regards the reporting requirement, an imprnvempnt has bseen made In the effect that it is no Longer mandatory for the seller only to discharge reporting obligations; instead, the buyer and the China company being indirectly transferred, in addition to the seller, may now voluntarily report the offshore transfer transaction by submitting 2 S2t of specified documents to the PRO tax authorities. In practice, it is noted that while it is not mandatory for either party to report the offshore transfer transaction to the PRO lax authorities under Announcement 7, more reporting have in fact been done for private transactions under Announcement 7 than historically under Circular 698, This is Largely attributed to the introduction and operations of the withholding provision under Announcement 7 that requires the buyer/ payer of transfer consideration to withhold the tax from payment to the sellers, as well as the introduction of penalty provision to punish buyers/ sellers for late payment of tax. As a result, many offshore sellers are now ‘forced’ by the buyers to report the transaction to the tax authorities as a condition precedent to transaction closing. Further, buyers in transaction would also often ask for the right to report the transaction and to withhold the tax liability with respect to the gain arising from the offshore transfer in order to minimise/ mitigate any penalties/ interest that may otherwise arise for the buyer on any underpaid/ under-withheld tax for the seller. Despite the improvement in Announcement 7 with respect to being much more comprehensive than Circular 698 through the clarifications on a number of issues, there are still areas which Announcement 7 have not yet specifically addressed, including:

i) Determination of the tax cost base for the calculation of taxable gains for the offshore seller; andii) Methodology for the allocation basis of sates consideration and acquisition costs where there are more than one Chinese assets and/or offshore companies being transferred, including the acceptable valuation techniques, calculation method and allocation approach.

In practice, it is noted that inconsistency exists in regard to the enforcement of Announcement 7 between different locations in the PRO. These matters have so far been up to taxpayers to discuss, negotiate and agree with the local tax authorities on a case-by-case basis. This clearly concerns many foreign investors who are mindful over their ability to comply with the laws and to maintain consistency in dealing with He Lax exposures.

It is hoped that a further supplementary notice will be issued in the future to clarify the current issues and remaining uncertainties in order to prevent inconsistencies in the enforcement of the new rules under Announcement 7.

Relaxation of corporate restructuring relief and CIT treatments an investments with non-monetary assets in China

A supplementary restructuring tax regulation was released Dy he SAT to facilitate China-inbound cross-border rvl&A and restructuring transactions.

Under the existing restructuring tax rules, Caishui [2009] No. 59 (Circular 59), to obtain tax relief for a share/ asset acquisition, the shares/ assets transferred will have to be at least 75 percent of the total shares/ assets of the target entity transferred. To improve the stringent criteria imposed under current provisions, Caishui [2014] No. 109 (!Circular 109] relaxes this ‘ratio limit’ to 50 percent.

Further, Circular 109 removes (i) the ownership requirement under Circular 59 for tax relief in relation to share/ asset assignment between PRO enterprises having a 100 percent direct holding relationship or are 100 percent under the same control provided certain conditions are met (including but not Limited to the transferee and transferee both not recognising profit/loss for accounting purpose), and (ii) the requirement under Circular 59 that The original main shareholder undertakes not to transfer the shares obtained within the following 12 months after the transaction is concluded. At the same time, the SAT released Caishui [2014] No 116 [Circular 116] in 2014 to volt out the CIT treatment for investments using, or in exchange for, non-monetary assets, which was previously only adopted for enterprises incorporated in the Shanghai FTZ, to the rest of China. In particular. Circular 116 allows PRC entities to pay PRO CIT over five years in relation to gains realized from transactions involving non-monetary asset exchanges. This should provide relief to businesses facing cash constraints on non-monetary assets settler M&A transactions. Further. Circular 116 also allows an entity to elect for the ‘special tax treatment’ under Circular 59 if the entity in conducting non-monetary asset exchanges also qualifies for ‘special. restructuring’.

Cross-border payments of services and royalties to overseas related parties

In terms of profit extractions from China to the overseas investors following their investments, it is not uncommon for overseas investors to extract profits out of China through service fees and royalties payments from PRO companies where Legitimate and commercially feasible; these profit extraction methods are generally more tax efficient than dividend repatriations as the PRO companies would generally obtain a tax deduction at 25 percent white the service fees and royalties income derived by the overseas recipient are subject to a tower tax charge.

That being said, such payments of service fees to overseas related parties has always been subject to close scrutiny by the PRC tax authorities. Historically, the challenge is mainly focused on whether the overseas service provider has created a taxable establishment in the PRC in relation to the services provision, or otherwise whether the service fee should be subject to CIT in China. RecentLy March 2015, the PRC SAT issued Announcement 16 regarding the deductibility of service fees and royalties paid by PRO companies to their overseas related parties for CIT purposes.

Specifically, Announcement 16 states that outbound payments of service fees and royalties should be conducted on an arm’s length basis; it also specifies certain types of service fees and royalties which should not be deductible for CIT purposes. These include [but not Limited to] payments of service fees to overseas related parties

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which do not economically benefit the PRO companies, and royalties paid to overseas related parties which makes no contribution to the value creation of the underlying intangible asset.

Announcement 16 wilt certainly have an impact on M&A transactions - for instance, historical structures used to drive tax efficiency by moving profits offshore through cross-border royalty and service payments will be under greater scrutiny with the result that the potential tax adjustments could be made by PRO tax authorities to increase the tax exposures of certain arrangements implemented by China target companies. This will be a focus in due diligence going forward.

Value Added Tax (VAT) reform and M&A

China has been progressively rotting out a reform since 2012 to extend VAT to services, in place of the existing Business Tax (BTI regime. Most services industries have now been transitioned to VAT, and it is expected that the remaining industries, such as real estate and construction, financial services and Lifestyle services, are set to transition to a VAT regime by mid-2016.

The VAT reform will likely have an impact to corporate bottom line. For example, the real estate and construction sectors will face a proposed VAT rate of 11 percent as opposed to the current BT rates of 5 percent and 3 percent, respectively. Without the ability to claim input credit taxes, the transition to a higher VAT rate will mean corporate profitability will be negatively impacted, which needs to be assessed in M&A transactions.

Looking ahead

A number of the expectations for 2014 remained unfulfilled at year end. The tong-awaited partnerships tax circular, which is needed to clarify the tax position of foreigners investing through Chinese partnerships. appears no closer to being released, On the other hand, it seems that the revised tax collection and adminIstration Law as wet’, as VAT reform implemention rules for the remaining services sectors will Likely be released in 2015. At the same time, given the developments of the Base Erosion and Profit Shifting LBEPS) initiative, the Chinese tax authorities would undoubtedly continue to incorporate these developments into its domestic tax regulations and enforcement practice.

While the investment climate for foreigners will potentially become more complicated if the current Draft Fl Law is finalised in the current form, the winds for cross-border M&A in China will continue to blow fair in view of the progress of investment climate and new initiatives being made during the year.

John Gu Partner, Tax KPMG China 8t1- Floor, Tower E2, Oriental Plaza Beijing 100738, China +86 10 8508 7095 john.gutdkpmg.com John Gu is a partner and tax leader for inbound M&A and private equity for KPMG 11:.:ina. He is based in Beijing and leads The national tax practice serving private equity clients. John focuses on regulatory and tax structuring of inbound M&A transactions and foreign direct

investments in the PRC. He has assisted many offshore funds and RMB fund formations in the PRC and has advised on tax issues concerning a wide range of inbound M&A transactions in the PRC in the areas of real estate, infrastructure, sales and distribution, manufacturing, and financial services.

Chris MakPartner, TaxKPMG China50th Floor, Plaza 66 1266 Nanjing West Road Shanghi 200040, China+86 21 2212 [email protected] Chris Mak has experience in advising multinational clients in the consumer, industrial and manufacturing industries in relation to appropriate corporate

holding and funding structures to conduct their proposed business activities in Australia. Since joining the Shanghai office, he has been heavily involved in assisting foreign companies on PRO tax issues arising from theft investment into China including proposed global. restructuring, company set-ups, Ike diligence, foreign exchange remittance issues and M&A transactions for the industriat, auto and real estate industries.

Yvette ChanDirector, TaxKPMG China 8th Floor, Prince’s Building 10 Chater Road, Central, Hong Kong+852 2847 5108 yvette.chaniakpmg.com Yvette Than has assisted a number of clients to undertake investments in the PRC with regard to transaction structuring and devising tax efficient

strategies for implementing PRC business operations and arrangements. She has also advised on a number of tax structuring, tax due diligence, tax modelling review, M &A, corporate restructuring, pre-IPO restructuring, teasing, and tax compliance projects in the PRO and specialises in the tax structuring of investment kinds, Nel &A and financial, transactions. Yvette services clients in a wide range of industries including private equity, investment fund, real estate, infrastructure (including toll roads, water treatment, electric power, and gas distribution], consumer and industrial markets (including chemical products), and financial. services.

Paul Ma Partner, Tax KPMG China 8th Floor, Tower E2, Oriental Plaza Beijing 100738, China +86 10 8508 7076 pauLmakpmg.corn Paul Ma is a China lax partner and an experienced M&A adviser, based in the KPMG Beijing office. He has extensive experience in advising regulatory and tax issues on cross-border investments, repatriation, financing, exits and post-deal integration. He has been involved in a large number of high profile

transactions covering a wide range of industries including financial services, technology, media and telecommunications [TMT), energy, real estate and consumer markets. He is also an expert in onshore and offshore private equity fund structuring.

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Hong Kong: Hong Kong tax increases attractiveness as an international financial centre

By Darren Bowdern and Malcolm Prebbte, KPMG China

2014 represented another record year for M&A activity in Asia, with the Largest transaction being the acquisition of the CITIC Group’s main operating unit by the Hong Kong Listed company, CITIC Pacific. The Hong Kong SAR Government has also been very active initiating a number of changes which should aid MA activity and continue to boost Hong Kong’s status as a beading global financial centre and important gateway to China.

Extension of the offshore funds exemption

An amendment ordinance has been enacted on 17 July 2015 to extend the existing offshore funds tax exemption to private equity (PE) funds.

The legislation has been tong anticipated and will be welcomed by the Hong Kong PE industry. The key features of the legislation include:• Extending the scope of transactions covered by the exemption to include investments in private companies incorporated outside of Hong Kong, This is naturally a key feature of a PE Fund’s business so this is a very important change▪ Exempting special purpose vehicles (SPVsJ, including Hong Kong SPVs, from Hong Kong profits tax on gains on disposal of a qualifying offshore portfolio company (this also includes gains by one SPV from the disposal of another SPV which holds a qualifying offshore portfolio company)• Loosening an existing requirement that qualifying transactions be arranged through a person \svith a Securities and Futures Commission ISFC1 License in order to rely on the Exemption. For offshore PE funds, the SEC license requirement has been removed where the fund has at Least five investors at its final close which have collectively committed more than 90 percent of the capital of the fund.

The introduction of an exemption for Hong Kong SPVs is an important change as it opens up the possibility for PE Funds to use Hong Kong companies to create an investment holding ptatform, In addition, there should be opportunities to amend existing operating procedures to make 1,ife easier for deal teams based in Hong Kong.

A number of PE Funds operating in Hong Kong are starting to consider hug they can benefit from the changes. Some of the issues being considered include:

• Whether changes should be made to existing operating protocols to allow more investment related decision making, board meetings and management oversight to take place in Hong Kong

• Ascertaining whether all types investments contemplated under a Fund’s existing mandate would be covered by the revised exemption, and if not, determining what needs to be done to mitigate the risk of non-qualifying investments tainting income generated from other investments

• Whether to establish a Hong Kong platform for holding investments in order to benefit from Hc ig Kong’s rapidly expanding tax treaty network

• What level of substance can or should be establlished in the investment holding SPVs having regard to both the scope of the revised exemption and also what is needed in the investee jurisdiction in order to quakfy for treaty benefits

• Assessing the impact of any changes made on existing transfer pricing arrangements to support advisory fees paid to Hong Kong investment advisors.

Hong Kong as a treasury hub

The Financial Secretary announced in his budget speech in February 2015 that the government would look to amend the taxation laws to allow, under specified conditions, interest deductions for Corporate Treasury Centres (CTCs) as well as a profits tax rate cut of up to 50 percent to firms setting up their CTC’s in Hong Kong.

The government hopes these proposed tax incentives will enable Hong Kong to compete, effectively, for companies Looking to establish CTCs in the Asia Pacific region and will help Hong Kong cement its position as a prime financial hub in the region.

The development of Hong Kong as a regional CTC hub would benefit Hong Kong’s financial and business sectors, and help deepen Hong Kong’s capital markets, including the offshore FMB market. It is Likely that the government’s recent announcement is targeting emerging Chinese and Asian multinationals looking to support international expansion and growth and for whom the case for setting up a CTC is compelling. The internationalization of the Renminbi and the emergence of the Renminbi trade settlement scheme, for example, have given additional impetus CTCs as they offer opportunities to hedge foreign exchange (FCC) exposure.

While many regard Singapore, as having an advantage over Hong Kong as a regional. Treasury centre location (global banking centre, concessionary tax rates, a common law legal system, a deep and liquid foreign exchange market, a pool of well-educated labour, a significant number of double taxation treaties, and a world class transport and telecommunications infrastructure], Hong Kong can claim many of the same advantages. In particular its network of double taxation treaties is generally of better quality and is expanding rapidly. Under the current proposal the Hong Kong tax rate for qualifying treasury centre income 18.25 percent] will actually be lower than Singapore (10 percent). and Hong Kong is looking to change the interest deduction rules, so that a Hong Kong CTC would no Longer be economically disadvantaged if it is funded by a non-HK company.

The proposed legislation is not expected before the last quarter of 2015, and a consultation period is Likely to take place beforehand. Once the consultation period is announced, further details of what activities would constitute a CTC are likely to be published, For example, must they be stand alone vehicles or could a CTC exist within a company with significant other activities. If the latter is permitted, how would one quarantine CTC income from other income?

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Tax treatiesDuring 2014 and 2015 Hong Kong increased its network of double tax agr6ements (DTA) to 32 with the conclusion of agreements with South Korea, South Africa and United Arab Emirates, Negotiations continue with over a dozen jurisdictions including Germany, India and Russia.

The further development of Hong Kong’s DTAs enhance its position as a regional. investment and trading centre. The Hong Kong government has reiterated its policy to conclude further OTAs and is prioritizing its major trading partners and jurisdictions that are the focus of Mainland Chinese outbound investment.

Global tax transparency

Hong Kong has consistently complied with ‘various OECD transparency initiatives while at the same time dealing with stakeholder concerns about the administration, privacy and privacy issues as well as the threat of potential capital withdrawal and the impact on its competitive advantage in Asia.

The OECD’s Common Reporting Standard ‘CRS) has been endorsed by the 020 as the global standard for the automatic exchange of financial information (AE01). CRS provides for the annual automatic exchange of financial account information between governments, including balances, interest, dividends, and sates proceeds from financial assets, reported to governments by -financial institutions, It also covers accounts held by individuals and entities, including trusts and foundations.

Hong Kong has committed to implement CRS and have its first exchange of information automatically in 2018.

Outlook for 2015

M&A activity has continued to grow during the first quarter of 2015 but may be impacted by recent financial market difficulties in China. Despite this, there should stilt be a number of Hong Kong based Asian focused PE Funds Looking to deploy significant new investor capital that has been raised over the past few years.

From a tax perspective, we expect to see Hong Kong paying particular attention to the outcomes and recommendations of the BEDS project and how these will impact Hong Kong taxpayers. We also foresee further government initiatives during the coming year that will maintain and increase the attractiveness of Hong Kong as an international financial centre which may also support the levels of M&A activity in 2015.

Darren BowdernPartner, TaxKPMG China 8th Floor, Prince’s BUI [dI rig 10 Chater Road Central, Hong Kong+852 2826 [email protected] Darren Bowdern is a partner in corporate tax. For more than 22 years, he has been involved in developing appropriate structures for investing into the Asia Pacific region, tax due

diligence reviews in connection with M&A transactions and advising on cross-border transactions. Many of these projects comprise tax effective regional planning including consideration of direct and indirect taxes, capital and stamp duties, withholding taxes and the effective use of double taxation agreements. He also advises on establishing direct investment, private equity and other investment funds in Hong Kong.

Malcolm Prebble Director, Tax KPMG China 8th Floor, Prince’s BuiLding 13 Chater Road Central, Hong Kong +852 2685 7472malcolm.j.prebbier@kpmg,corn tvlalco[rn Prebb[e is a director in KPMG’s Hong Kong M&A tax team, He has extensive experience in advising on regionaL M&A projects incLuding

tax due diLigence and structuring projects for acquisitions by fund organisations and other professional investors. Through this work he has developed significant expertise in issues associated with cross border structures and is familiar with specific structuring issues associated with investments into a number of countries within Asia Pacific. He has advised ctients in a wide range of industries, including manufacturing, infrastructure, rear, estate and private equity.

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