Transfer pricing is a pervasive tax issue among multinational companies. In Vietnam, the tax authorities require special documentation to report related party transactions. Compliance with transfer pricing regulations is an important aspect of doing business effectively in Vietnam as failure to do so may result in significant penalties.

PLANNING

Transfer pricing planning gives all-around consideration to commercial viability, tax efficiency and transfer pricing compliance. It allows you to be confident that your transfer pricing policy and practices integrate well with your broader operational and tax considerations.

RISK ASSESSMENT

Analyse and locate your existing and potential Vietnam transfer pricing risks taking into consideration the business and transactional model, price setting, FAR profile, and recommendations for improvement.

ECONOMIC ANALYSIS

A benchmarking study establishes an appropriate arm’s length price by reference to comparable transactions or profit outcomes of independent companies with similar transactions and in similar conditions to the tested entity. It is an essential element of contemporaneous documentation and a crucial support to identify the re-assessed prices to be disclosed in annual Transfer Pricing fillings. Powerful competitive market insights can also be achieved.

TRANSFER PRICING DOCUMENTATION

Contemporaneous documentation to support related-party transactions can help avoid penalties. Accordingly, it is important to clearly document that the arm’s length principle is being followed, and how pricing decisions have been made for such transactions.

ASSISTANCE IN COUNTRY-BY-COUNTRY REPORTING AND REPARING MASTER FILE

Provide appropriate information for purposes of compliance of the Group as well as investigations on the Group’s supply chain under the program of Base Erosion Profit Shifting (“BEPS”) Action Plan.

DISPUTE RESOLUTION

Dispute resolution supports companies subjected to transfer pricing audits. This is achieved by preparing defense packages and negotiating with the tax authorities, instilling confidence and removing any confusion around your transfer pricing position.

PREPARATION OF DISCLOSURE FORM

Support in reviewing/ collating relevant accounting figures and performing the benchmarking support to identify the arm’s length prices for disclosure on the Form.

Nguyen Dinh Du Partner Contact