P0
Engagement and authorisation
Entry gate The engagement letter is signed and at least 70% of the starred document requests are in hand. Below 70% we do not mobilise — waiting for documents on site burns the budget for nothing.
Services
From the dispute itself, to the controls that stop the next one.
Our work runs along three practice lines. They share one evidentiary standard and one set of project disciplines; what differs is the point at which we are brought in — after a dispute has arisen, or before.
01 — Practice one
Tax controversy
Once a company and the tax authority genuinely disagree on the facts or on how a rule applies, the question is no longer whether the accounting was right. It is whether you can produce evidence and reasoning the other side will accept. This is our oldest and most central practice.
Audit defence and written representations
Case analysis, evidence gathering, drafting of representations and evidence bundles, and preparation for hearings.
VAT disputes
Applicable rates and levy rates, input tax reversals, deemed sales and the export refund basis — response and supporting evidence.
Corporate income tax disputes
Deduction vouchers, revenue recognition timing, asset losses and challenged incentive eligibility — response and recomputation.
Individual income tax disputes
Equity transfer pricing, shareholder loans, equity incentives and pay structure adjustments, including allocation of withholding responsibility.
Social insurance disputes and employment compliance
Contribution base assessment after the transfer of collection, retrospective payment and disputes over employment models, through to compliance remediation.
False-invoicing findings and abnormal vouchers
Rebuilding the evidence chain for commercial substance where input credits are challenged, an upstream supplier is listed abnormal, or a third-party entity was used to invoice.
Administrative review and litigation support
Specialist tax and accounting support through review and litigation, working alongside instructed counsel on the facts and the computation.
Land appreciation tax settlement disputes
Disputes over settlement methodology, cost allocation and deductible items, including re-preparation of the settlement filing.
Upstream and downstream investigations
Responding when a counterparty is reclassified and the authority requests explanations and supporting materials from your company.
Cross-border and transfer pricing disputes
Treaty application, transfer pricing documentation and advance pricing arrangements — both prevention and defence.
02 — Practice two
Financial advisory
Advisory addresses the structural problem: the business process determines the documentation, the documentation determines the tax outcome, and the corporate and shareholding structure sets the boundary of both. We work as retained advisers or on defined projects.
Tax compliance and effective rate structure
Eligibility analysis for incentives, tax burden modelling, option comparison and follow-through on implementation.
Tax health checks and monitoring
Periodic diagnostic reporting across invoicing, VAT, corporate income tax, individual income tax and other taxes.
Books rebuild
Diagnosis, clean-up, adjustment and restatement where the books diverge from reality, with a rebuild report on completion.
Finance function design
Departmental structure, role definitions, internal controls, costing framework and standard operating procedures.
R&D expenditure compliance framework
From project initiation, timesheet and cost capture rules to the auxiliary ledger and retained supporting files, making the super-deduction a standing routine rather than a scramble at year-end filing; R&D Steward handles the capture, the caps and the risk checks.
Corporate and shareholding structure
Business model analysis, structure design, tax cost modelling and an implementation path.
Budgeting and treasury
Three-year rolling budgets, variance analysis, cash runway forecasting and management dashboards.
Full-cycle IPO readiness
Pre-listing clean-up and financing, coordination of advisers and filing materials during the process, and continuing compliance afterwards.
International and cross-border tax
Cross-border planning, offshore incorporation and finance agency, treaty research and trade tax advice.
03 — Practice three
Forward-deployed delivery
Forward-Deployed Engineering is the delivery model we have developed in recent years: the tooling is installed at the client site, and our own professionals gather the evidence and form the judgement there. What can be automated is compressed to the minimum; what cannot is staffed honestly. Internal audit is only one of the lines — all six tools on the technology page are delivered this way.
Internal audit and control frameworks (Neishentong + CFAudit)
Audits run on working papers written for the specific company rather than a generic template. Working papers as code, reconciliations as assertions, producing conclusions fit for external use.
Related-party pricing review
Benchmarking against genuine third-party transactions, line by line by specification and period, turning a structural view into a negotiable figure.
Commercial substance and fund tracing
Inventory observation, goods-movement document testing and reconciliation of invoice descriptions to physical goods; all bank statements obtained and traced to test whether the ledger is complete and off-book cycles exist.
Tax risk scanning and remediation (Anxinshui)
264 risk models are run against 36 months of filing and invoice data on the client's own machine; we then work each finding through to remediation and quantify the incentive clawback exposure along the way.
Management dashboard and cash-flow management (Jingying Tongbao)
Nine classes of exported finance tables are recognised automatically and a dashboard is built locally: profit-and-loss rankings by product and customer, loss-making orders, credit-limit breaches, related-party triangulation, slow-moving stock analysis and cash-flow management, with the finance team trained to run it monthly.
Cross-border compliance (Cross-border Steward)
On site we connect the regional cross-border e-commerce service platforms and get 9610 / 9710 / 9810 / 1210 declaration, AI-assisted HS classification and export refund ledgers running.
Materials, labour, overhead and tax
On-site cost reduction for factory manufacturing: lean production, overall equipment effectiveness (TRS / OEE) equipment effectiveness analysis, man-machine efficiency ratios and economic order quantity used together, measured on inventory turnover and unit cost.
Sales enablement delivery
Six modules of training, question bank, case library, stage-by-stage playbook and certification delivered as one working system inside the client's organisation, with us alongside during rollout.
Policy drafting and remediation tracking
Drafting procurement authority, related-party recusal, pricing and treasury policies, then tracking each remediation item monthly to closure.
Tool localisation and role training
Deploying the tooling on the client's own machines and training audit, finance and commercial staff to run it independently every month.
04 — Project discipline
Seven stages, each with an explicit entry gate
A stage does not begin until the gate is met — this is the only reliable way to stop an on-site engagement from running away. The workflow below is set out for an internal audit engagement; the other lines follow the same gate logic, tailored to scope.
P1
Data ingestion
Entry gate The build passes and the regression ties to previously verified figures. If it does not tie, the extraction basis is wrong and the work stops there.
P2
Automated testing
Entry gate A written field plan exists, stating which working paper and which conclusion grade each on-site procedure is meant to deliver.
P3
Field verification
Entry gate Every finding lands on one of three states: confirmed, cleared, or evidence insufficient. "Still to be checked" may not enter the report.
P4
Conclusions and reporting
Entry gate Every figure in the report traces to a line in a source document. A figure without an evidence index does not go in.
P5
Policy build and remediation
Entry gate All remediation items are closed and the key metric turns positive when the core working papers are re-run. If the metric has not moved, remediation is not complete.
P6
Tool localisation and training
Entry gate The client's internal auditors can load data, run the working papers, read the exception list and maintain the related-party register unaided.
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Re-review and annual revisit
Entry gate All automated working papers are re-run and compared against the prior baseline, with a re-review opinion issued.
Field verification usually accounts for more than half the effort on an engagement, and most of it is inventory observation, confirmations, site visits and interviews — Tier 4 evidence that an auditor must obtain in person and that automation cannot compress by a single day. Anyone claiming to have fully automated internal audit either does not understand auditing, or is about to have an accident.
Have a specific problem and want a professional view on it?
Tell us the facts and we will tell you what kind of problem it is, how it is normally handled, and how far it can realistically be pushed on the evidence you have.