Xuefeng Leng

Practice Areas

税收咨询、税务合规、税收规划、税务自查协助与稽查应对、税务争议解决、涉税刑事辩护

Tax Advisory, Tax Compliance, Tax Planning, Assistance with Tax Self-Review, Response to Tax Inspection, Tax Dispute Resolution, Criminal Defense in Tax-Related Offenses, Cross-Border Tax Legal Services

Career

冷雪峰律师专注于税收法律服务领域，业务类型几乎涵盖了全部涉税法律服务内容，其具备律师、注册会计师等多项专业资质，能够熟练运用法律、税收、财务及金融等综合领域专业知识，结合在税务机关期间税务稽查与税收征管的双条线复合工作经验，善于从税务机关与纳税人两个不同视角出发综合思考并最终落地解决各类涉税问题。

Leng Xuefeng specializes in the field of tax legal services, with his practice covering virtually all aspects of tax-related legal matters. He holds multiple professional qualifications, including attorney-at-law and certified public accountant, and is proficient in leveraging interdisciplinary expertise in law, taxation, finance, and accounting. Drawing on his dual-track experience in tax inspection and tax administration during his tenure at the tax authorities, he excels at analyzing and resolving diverse tax-related issues from both the perspectives of tax authorities and taxpayers, ultimately delivering comprehensive and actionable solutions.

Professional Memberships

律师，中国注册会计师

Practicing lawyer, Chinese Certified Public Accountant (CPA)

Personal

冷雪峰，高级合伙人，曾在税务机关工作多年，深耕税收法律服务领域近20载，主办了大量重大疑难税务案，累计为纳税人降低税收成本损失近110余亿元；主办的逃税罪等涉税刑案均取得无罪、撤销案件等有效成果；其在资本市场、股权激励等非诉领域所涉税务合规、税收规划等方面亦为客户提供了合规可行且具有前瞻性的法税综合方案。

Leng Xuefeng, Senior Partner, brings nearly two decades of deep expertise in tax legal services, following extensive prior experience within the tax authorities. He has led a significant number of major and complex tax cases, successfully reducing tax-related costs and losses for clients by a cumulative total of over RMB 11 billion. In criminal tax matters, such as tax evasion cases, he has consistently achieved effective outcomes including acquittals and case dismissals. Furthermore, in non-contentious areas including capital markets and equity incentive plans, Mr. Leng provides clients with compliant, practical, and forward-looking integrated legal and tax solutions for tax compliance and planning.

Clients

中国国际航空集团公司、中信保诚、天弘基金、小米集团、香港新世界地产、韩国晓星、博汇股份、精工控股、中国燃气、中节能集团、香江国际发展有限公司、国家开发银行、深圳市特发集团、中国中煤能源集团公司、合景悠活控股集团有限公司、云南磷化集团、奥地利奥合国际银行、奥凯航空、大田物流等。

Air China Group Corporation, CITIC Prudential​, TianHong Asset Management Co., Ltd., Xiaomi Corporation, New World Development Company Limited​, Hyosung Corporation, Bohui Chemical Technology Co., Ltd., Seiko Holdings Corporation, China Gas Holdings Limited, China Energy Conservation and Environmental Protection Group (CECEP), Heung Kong International Development Limited, China Development Bank, Shenzhen Special Economic Zone Development (Group) Co., Ltd., China National Coal Group Corporation, Hopson Living Holdings Group Co., Ltd.​, Yunnan Phosphate Chemical Group Co., Ltd., Raiffeisen Bank International AG (RBI)​, Okay Airways, DTT Logistics, etc.

Work Highlights

1. [税收争议解决类]深圳某房地产集团及8家关联企业与税务稽查机关系列偷税行政争议案件（涉案税款、滞纳金、罚款共计90余亿元，涉及税务行政处理、税务行政处罚、不予确认纳税担保、延期缴纳税款、延期缴纳罚款等各类税收争议，在行政诉讼阶段接受委托，协助企业依法诉讼，法院最终判决撤销税务处罚决定及偷税认定，税务稽查机关依据生效的司法判决撤销税务处理决定，协助税企重新依法复核，实质性化解税企分歧）

[Tax Dispute Resolution] A real estate group in Shenzhen and its eight affiliated companies were involved in a series of administrative disputes over tax evasion with tax inspection authorities. The total amount in dispute, including overdue taxes, late fees, and fines, exceeded RMB 9 billion. The case covered various tax-related disputes, such as tax administrative decisions, tax administrative penalties, refusal to recognize tax guarantees, deferral of tax payments, and deferral of penalty payments. After being engaged during the administrative litigation stage, legal counsel assisted the companies in filing the lawsuit in accordance with the law. The court ultimately ruled to revoke the tax penalty decision and the determination of tax evasion. In compliance with the effective judicial ruling, the tax inspection authorities revoked the tax administrative decision. Legal counsel then assisted both parties in conducting a new lawful review, effectively resolving the disputes between the tax authorities and the enterprises.

2.[税务自查协助类] 宁波某石化行业上市公司消费税征纳与退税征管风险自查应对与争议化解案件（涉案税款4.7余亿元，协助企业在被主管税务机关要求自查补税阶段依法沟通磋商，启动法定程序撤销并否定征税文书，协助企业依法享受退税政策并申请4余亿元退税，避免企业被移送税务稽查，实现税企分歧在征管前端的实质性化解）

[Assistance with Tax Self-Review] Case of Self-inspection, Risk Response, and Dispute Resolution Regarding Consumption Tax Collection, Payment, and Refund Administration for a Listed Petrochemical Company in Ningbo​ (This case involved tax amounts exceeding RMB 470 million. The company was assisted in conducting lawful communication and negotiation during the phase when the competent tax authority required self-inspection and supplementary tax payment. Legal procedures were initiated to revoke and invalidate the tax assessment documents. Furthermore, the company was assisted in lawfully availing itself of the tax refund policy and applying for a refund of over RMB 400 million. This prevented the case from being referred to tax inspection authorities, achieving a substantive resolution of the dispute between the enterprise and the tax authorities at the preliminary stage of tax administration.)

3. [税务稽查应对类] 某上市公司及其内蒙古子公司税务稽查应对案件（在稽查阶段，向税务稽查机关提交法律意见并进行陈述申辩，协助企业降低税收成本损失4800余万元，企业最终未被定性偷税并不予行政处罚，实现稽查程序中税企分歧的实质性化解）

[Response to Tax Inspection] Case of Tax Inspection Response for a Listed Company and Its Subsidiary in Inner Mongolia​ (During the audit stage, legal opinions were submitted to the tax inspection authorities, and statements and defenses were presented, assisting the company in reducing tax-related costs and losses by over RMB 48 million. The company was ultimately not classified as having committed tax evasion and received no administrative penalties, achieving a substantive resolution of the dispute between the enterprise and the tax authorities during the audit procedure.)

4.[涉税刑事辩护类] 某房地产企业实际控制人涉嫌逃税罪案（涉案税款金额18余亿元，法院判决无罪）

[Criminal Defense in Tax-Related Offenses] Case Involving the Actual Controller of a Real Estate Enterprise Suspected of Tax Evasion​ (The amount of taxes involved exceeded RMB 1.8 billion. The court ruled not guilty.)

5.[税务合规类] 为韩国晓星电脑公司实施专项税收合规性审查法律服务

[Tax Compliance] Provision of Special Tax Compliance Review Legal Services for Hyosung Computer Company of South Korea

6.[税务规划类] 为中航集团整体处置国航大厦项目提供不动产处置方案与税收规划法律服务

[Tax Planning] Provision of Legal Services on Real Estate Disposal Solutions and Tax Planning for the Overall Disposal of the Air China Building Project for China National Aviation Holding Corporation

7.[税收咨询类]

[Tax Advisory] Provision of Annual Tax Advisory Legal Services to CITIC Prudential and Its High-Net-Worth Clients

8.[跨境税收法律服务类]

[Cross-Border Tax Legal Services] Provision of Tax Legal Analysis and Tax Solution Services for the Overall Sale of Domestic Assets in China by American AgFeed Industries, Inc. (a NASDAQ-listed Company)​ (Selected by The M&A Advisoras the 2013 International M&A Deal of the Year / Agriculture Deal of the Year)

9.[丧失救济权利后成功重启法定救济程序类]广州某高新技术企业被税务稽查机关实施税务检查，税务稽查机关作出税务处理决定后，企业未在法定60日内申请行政复议，时隔一年半后，协助企业依法成功就税务处理决定申请行政复议并被复议机关受理

[Successful Restart of Statutory Remedy Procedures After Loss of Relief Rights] A high-tech enterprise in Guangzhou underwent tax inspection by the tax authorities, resulting in a tax treatment decision. The enterprise failed to apply for administrative reconsideration within the statutory 60-day period. After a year and a half, with professional assistance, the enterprise successfully applied for administrative reconsideration of the tax treatment decision in accordance with the law, and the application was accepted by the reconsideration authority.

Industry Sector Expertise

互联网企业、房地产、石化企业、矿产能源、制造业、金融业、再生资源行业、商业服务业、物流行业、农产品加工业、航空业、高净值人士及其家族财富传承等领域的全方面税收法律服务

Comprehensive tax legal services for Internet enterprises, Real estate, Petrochemical companies, Mining and energy, Manufacturing, Financial industry, Renewable resources sector, Commercial services, Logistics industry, Agricultural products processing, Aviation industry, High-net-worth individuals and family wealth succession, among others.

Expert in these Jurisdictions

中国

PRC

Languages Spoken

中文、英文

Chinese, English

Experience

2007.8至今 北京大成律师事务所

2005.6至2007.8高级合伙人 北京金诚同达（沈阳）律师事务所

1998.8至2005.6 沈阳税务局

2007.8-now Dacheng Law Offices,LLP

2005.6—2007.8 JinChengTongDa&Neal Shenyang Office

1998.8—2005.6 Tax Authority

Education

Awards