Today’s tax controversy landscape represents a perfect storm of competing factors. Tax audits are more aggressive and contentious than ever before. Examinations and appeals are increasingly difficult to settle without significant additional tax or reputational impact. At the same time, taxpayers must be more transparent following the introduction of far more onerous disclosure requirements imposed under Decree 20 and Circular 41. These requirements include local file, master file, country-by-country reporting and annual compliance reporting).
Vietnam’s tax authorities recently established dedicated transfer pricing audit teams in provinces throughout Vietnam and continue to aggressively pursue taxpayers through the tax audit process. Familiarity with the tax audit process, full compliance and an understanding of the tax authority’s assessment of the key risks areas are critical success factors. PwC Vietnam’s market leading government liaison and tax investigations practice has supported many companies in this regard toward successful conclusion of the dispute.