Our Services

TRANSFER PRICING

How we can help

Transfer pricing is considered the most important international tax issue facing business operations of companies operating across borders. However, the laws surrounding transfer pricing are becoming ever-more complex and today, and tax affairs of multinational companies are facing scrutiny from media and the public. 

Especially since the Organization for Economic Co-operation and Development (“OECD”) published the final report related to Base erosion and profit shifting (“BEPS”) Action 13 “Transfer Pricing Documentation and Country-by-Country Reporting” in 2015, Vietnam has implemented these OECD recommendations by introducing the new legislations to replace the old regulations and setting up the dedicated substantial team to conducting the transfer pricing audit through the nationwide. 

In Vietnam, Decree No. 20/2017/ND-CP dated 24 February 2017 has been issued to regulate and to provide guidelines on preparation of declaration forms and documents for determination of associated transaction prices. These regulations and guidelines are one of the most disputable arenas of tax, which require a substantial technique and information to comply with. Our transfer pricing experts will work with you to develop a transfer pricing strategy suited to your multinational company. 

Our Transfer Pricing experts will help you create strategic advantage by using transfer pricing as a core management tool and deal with various issues of tax, so that you can focus on your business objectives. 

Per our practical observations, the areas focused by Vietnam tax authorities are as follows:

• Low margins over the years
• Continuous losses over the years
• Different transfer prices over the years
• Fluctuation in margins over the years
• Losses in some years or in some divisions
• Cost sharing arrangements
• Group restructuring
• Permanent establishment (“PE”) issues
• Production capacity management
• Royalty/ management fees payments

Our Services

• Assistance in compliance obligations (preparation of transfer pricing documentation including local file, master file and country-by-country report and related party transactions disclosure returns)
• Preparation/ Review of supporting transfer pricing documentation and policies
• Transfer pricing planning and structuring
• Transfer pricing dispute solution
• Transfer pricing training