Our core competencies
Vietnam first transfer pricing regulations were introduced at the end of 2005 and came into force in 2006. Through over 10 years of implementation, it can be seen that Vietnam transfer pricing enforcement has been enhanced significantly.
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.
At RSM our integrated national and international network of transfer pricing specialists will assist corporate taxpayers to meet their specific and unique transfer pricing requirements. These experts work collaboratively with international tax teams in order to optimize the commercial and fiscal structure of multi-national groups. Our expertise covers both industry specific and transaction based transfer pricing issues.
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
- 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