ENG

  • Mark GAO

    Equity Partner / Shanghai

  • Tel +86-21-6061-3666

    Email markgao@zhonglun.com

  • Practices

    Taxation & Wealth Planning

  • Industries

    Telecom & Information, Pharmaceuticals & Life Sciences, Media, Sports & Entertainment

CV

Mark GAO

Before joining Zhong Lun, Mark Gao worked for five years as a senior tax consultant at its Shanghai office of a German tax consulting firm.

With more than 16 years of experience in tax and wealth planning practice for both companies and individuals, Mark has exhibited considerable expertise in tax compliance and planning in cross-border M&A, investment and financing, company restructuring, and daily business operation. In addition, Mark is well-versed in tax-related dispute resolution, offering services including acting as tax expert for cross-border disputes, representing various Chinese central state-owned enterprises and private-sector businesses in tax administrative appeals and litigations, and devising effective tax dispute resolution strategies for companies. His proficiency extends to the domains of the sharing economy, flexible employment, and tax planning of ultra-high-net-worth individuals (including offshore family trust matters and employee benefit trust planning). Notably, Mark has successfully represented clients in negotiations with both PRC national and provincial tax authorities. For these representations, he has implemented feasible tax planning strategies, proactively addressed tax inspections, and adeptly managed tax-related conflicts.

In the private wealth planning area, Mark has been focused for many years on providing legal services to ultra-high-net-worth individuals, especially in the areas of offshore and domestic trusts, employee benefit trusts, and cross-border estate planning. Notably, in the new economic industry, Mark has represented hundreds of internet, high-tech, and unicorn companies and their founders and senior executives in setting up their offshore family trusts and employee benefit trusts.

Mark's clients operate in various sectors, including the internet, high-tech, biopharmaceuticals, investment fund, entertainment, media, sports, manufacturing, real estate, energy, trade, and professional services. Furthermore, he acts as tax and legal advisor to many single-family offices of the top ultra-high-net-worth individuals and provides several renowned families with cross-border tax and investment structuring services.

Mark has been recommended by esteemed legal directories such as Chambers and The Legal 500 for many consecutive years. Recognized as a Leading Individual in the private wealth practice area by The Legal 500 from 2024 to 2026, he is among the very few practitioners to receive key endorsements in both taxation and wealth planning. Mark is regularly sought after to deliver presentations on tax and wealth planning at domestic and international private banks, investment firms, and emerging media platforms.

As a prominent figure among Chinese tax and wealth planning lawyers, Mark is frequently invited to give speeches and deliver presentations on the progress and transformation of the Chinese tax landscape at various international tax conferences and prestigious universities.

Representative Matters

Tax Consulting and Planning

  • Provided PRC tax advice and tax filing services to several international leading funds on direct and/or indirect transfer of PRC assets

  • Provided comprehensive China-related tax services for cross-border asset divestment transactions of multiple multinational listed groups, covering tax advisory, tax filing, and tax payment, assisting clients in successfully completing the transactions

  • Provided tax advisory services for the FIFA World Cup and other events

  • Advised Tencent on the privatization of a number of listed companies

  • Provided tax advisory and planning services for the operation and investment activities of a number of single family offices

  • Provided tax advisory and planning services to a number of listed companies in connection with the exit of their founders' shareholdings


Tax Dispute Resolution

  • Represented a Fujian-based subsidiary of a central SOE in the steel industry in both administrative reconsideration and litigation proceedings concerning the compliance assessment of VAT invoices for goods procurement, with the disputed tax amount exceeding CNY 100 million

  • Provided tax consultancy and dispute resolution services for multiple subsidiaries (including those in Hainan and Hebei) of a central state-owned energy company in relation to VAT invoices, including representing the company in administrative reviews and administrative litigation

  • Represented a Shanxi-based subsidiary of a central SOE in the steel industry in both administrative reconsideration and litigation proceedings concerning a corporate income tax treatment dispute, involving disputed taxes and late payment surcharges exceeding CNY 100 million

  • Represented a Dalian-based pre-IPO manufacturing enterprise in an administrative litigation concerning a personal income tax dispute, successfully securing an exemption from administrative penalties for the client and thereby facilitating its IPO process

  • Provided VAT and land value-added tax related dispute resolution services to a number of real estate companies, including representing the companies in administrative review and administrative litigation

  • Assisted a well-known domestic gaming enterprise in responding to tax inspections by authorities in several provinces, centering on its eligibility for tax incentives applicable to software enterprises and super-deductions for R&D expenses

  • Assisted a real estate agency enterprise in responding to tax authority inspections, primarily addressing tax assessment and collection matters, while concurrently coordinating the response to an audit conducted by a specific dispatch office of the National Audit Office

  • Provided tax expert opinions as an expert witness in more than ten litigation and arbitration cases in Switzerland, Hong Kong SAR, and Singapore


Wealth Planning

  • Advised a high-profile family that owns a leading A-share listed enterprise in the nutritional health food industry on comprehensive planning services, including the establishment of a domestic trust, the drafting of a family constitution, as well as the structuring and implementation of a family office

  • Provided family trust services to a number of co-founders and executives of a Hong Kong-listed technology company

  • Provided family trust and family office related tax services to the founder and co-founders of a Hong Kong-listed F&B headquartered company

  • Advised multiple founders and executives of a US- and Hong Kong dual-listed new energy vehicle (NEV) company on establishing family trusts

  • Provided family trust services to the founders of a number of gaming companies

  • Provided overseas family trust tax and legal services to the executives of a Hong Kong-listed Internet company

  • Advised the founder of a leading fund on implementing a dual-trust structure comprising an offshore family governance trust (FGT) and an onshore PRC FGT to manage his global and domestic assets, while providing comprehensive U.S. pre-immigration tax planning ahead of his spouse’s relocation, ensuring cross‑border compliance, tax efficiency, and unified family governance

  • Provided full-process legal advice to the domestic subsidiary of an overseas listed company on the compliance of the founder's overseas family trust in the listing process, and helped the subsidiary to list in China

  • Assisted the founder of a Nasdaq-listed company in restructuring his trust arrangements by changing the trustee of an existing trust and establishing a new trust to hold his diversified business investments, optimizing the cross-border governance framework, enhancing asset protection, and ensuring compliance across multiple tax jurisdictions

  • Provided executive and employee incentive trust services to over 50 companies listed (including proposed to be listed) in the US and Hong Kong, covering biotechnology, high-tech, internet, consumer goods, semiconductor, and other industries

Honors and Awards

Tax

Band 2 in Tax (PRC Firms), Chambers Greater China Region, 2026

Band 3 in Tax (PRC Firms), Chambers Greater China Region, 2024-2025

Up and Coming in Tax (PRC Firms), Chambers Greater China Region, 2022-2023

Next Generation Partners in Tax: PRC Firms, The Legal 500 Rankings, 2017-2025

Private Client/Wealth Management

Band 2 in Private Wealth Law (PRC Firms), Chambers High Net Worth Guide, 2025

Band 3 in Private Wealth Law (PRC Firms), Chambers High Net Worth Guide, 2023-2024

Up and Coming in Private Wealth Law (PRC Firms), Chambers High Net Worth Guide, 2021-2022

Band 2 in Private Client/Wealth Management (PRC Firms), Chambers Greater China Region, 2026

Band 3 in Private Client/Wealth Management (PRC Firms), Chambers Greater China Region, 2025

Band 4 in Private Client/Wealth Management (PRC Firms), Chambers Greater China Region, 2024

Leading Individuals in Private Wealth: PRC Firms, The Legal 500 Rankings, 2024-2026

Next Generation Partners in Private Wealth: PRC Firms, The Legal 500 Rankings, 2023

General Recognition

Outstanding Young Lawyer in Pudong New Area, 2024

Young Lawyer of the Year: Yangtze River Delta - Non Local, ALB, 2025

Young Lawyer of the Year: East China - Non Local, ALB, 2023

Memberships & Affiliations

Deputy Chairman, Pudong New Area Young Lawyers Federation

Officer, Pudong Lujiazui New Social Stratum Association

Related

  • Bar Admissions/Professional Qualifications

    PRC Bar
    CTA

  • Education

    CTO Academy, Shanghai Jiao Tong University
    LL.B., Shanghai International Studies University

  • Professional Experience

    Partner, Zhong Lun Law Firm
    Senior Tax Consultant, WTS Tax Consulting Firm Shanghai Office

  • Languages

    Chinese
    English