Intra-group management services are a controversial and highly debated tax issue in Vietnam. In this article, DFDL tax and transfer pricing experts share their insights on the tax and transfer pricing aspects of providing intra-group management services to Vietnamese subsidiaries of multinational enterprises. This article discusses Vietnam’s Benefits Test, pricing for intragroup services, relief under tax treaties, deductibility of intra-group management service fees, and practical tips and recommendations for taxpayers to manage Vietnamese tax risks.
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The information provided here is for information purposes only and is not intended to constitute legal advice. Legal advice should be obtained from qualified legal counsel for all specific situations.
