Vietnam Transfer Pricing Highlights 2016 examines the transfer pricing environment in Vietnam, which has rapidly evolved in recent times. Since the introduction of the National Action Plan, several audits focused on related party transactions have been conducted both by the provincial tax departments and the General Department of Taxation (GDT). Soon after, special teams within the GDT have been created with a focus on transfer pricing enforcement, a move that indicates the determination and aggressiveness of Vietnam’s tax authorities in bridging “gaps” in this area and ensuring taxpayer compliance is enhanced and enforced.
Given 2016 will be a busy year, with the tax audits including transfer pricing to be initiated now following the tax return filing deadline at the end of March, the time is right for companies to revisit their existing TP reports and supporting documentation, with a view to developing a robust and defensible position in the event of scrutiny.
The Transfer Pricing Highlights examine the following areas:
- Vietnam transfer pricing environment
- Compliance requirements
- Determination of related party
- Tax return disclosures
- Contemporaneous transfer pricing documentation
- Advance Pricing Agreement (APA)
- High-risks areas
- Potential high transfer pricing risk targets
- Intra-group service charges
- Management fees
- Highlights of transfer pricing audit
- Period covered under audit
- Tax impact and penalties
- Secret local comparables
- Handling transfer pricing audit and negotiation process
- Our recommendations.