Tax dispute resolutions

What is the current state of tax controversy?

Today’s tax disputes and controversy landscape represents a perfect storm of competing factors. The Vietnamese tax authorities are increasing their enforcement efforts and are focusing on business tax compliance and international tax issues such as transfer pricing and VAT on the export of goods/services as well as more traditional areas such as tax incentives and the lack of appropriate supporting documentation.  

Tax audits are becoming more contentious and seemingly increasingly difficult to settle. The provincial tax authorities and the General Department of Tax (GDT) are challenging taxpayers more aggressively due to tax collection demands and at the same time, taxpayers are required to be more transparent and remain fully compliant with an ever changing tax system.  The size of tax exposures are becoming ever more significant and a strategic approach to tax disputes and controversial tax matters is now more important than ever.   


How can companies prepare?

Companies can minimise disruption to their business operations by taking steps to prevent tax disputes, proactively manage them when they arise and resolve them in a timely and favourable manner.  Planning ahead by undertaking a tax risk assessment or ‘health-check’ is a viable strategy for many companies as is a stand-alone technical assessment of specific unclear or contentious areas.

With an experienced team of dedicated government liaison and tax disputes specialists which are widely seen as market leaders our team is uniquely qualified to advise taxpayers during each phase of the tax dispute life cycle.  Contact our team today to see how we can help you address unclear or contentious tax matters or assist in your tax audit dispute

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How can PwC help?

PwC’s tax controversy and government liaison team offers unrivalled insight and understanding of the workings of the Vietnamese tax authorities and the approach they adopt to contentious issues and tax audits, helping companies during each phase of a tax audit or assisting them in addressing controversial or unclear tax matters by:

Helping companies ‘get ahead of the issue’ by proactively limiting tax risk

  • Defence file preparation
  • Strategic risk assessment/mock audits and tax health-checks
  • Assistance in obtaining official letters and rulings
  • Advance pricing agreements
  • Industry issue resolutions
  • Obtaining and interpreting regulations and other guidance
  • Refiling and voluntary disclosures
  • Advisory opinions

Streamlining and shortening the audit process and resolving issues at a provincial or General Department of Tax / Ministry of Finance level

  • Negotiate scope and timing of audit
  • Advise best practices for answering document requests
  • Identify risks and develop taxpayer submissions and strategy
  • Resolve issues at the examination level
  • Elevate issues ‘up the chain’ at taxing authority, when appropriate
  • Liaise with the authorities based – identifying and accessing the right people and the best strategic approach to resolution 

Analysing litigation hazards, developing defence strategies, exploring alternative dispute resolution opportunities, and advocating for successful dispute resolution

  • Review tax findings and total tax exposure assessment
  • Assistance with tax audit appeal process
  • Competent authority negotiations
  • Treaty-based binding arbitration
  • Litigation support 

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Get in touch

Nguyen Thanh Trung

Nguyen Thanh Trung

Partner, Tax Services Leader, PwC Vietnam

Tel: +84 28 3823 0796

Nguyen  Huong Giang

Nguyen Huong Giang

Partner, Tax Services, PwC Vietnam

Tel: +84 24 3946 2246

Do Ngoc Lan Thanh

Do Ngoc Lan Thanh

Director, Tax services, PwC Vietnam

Tel: +84 24 3946 2246 Ext. 3023