Transfer pricing documentation

Global trends driving local change

Tax authorities worldwide are imposing new, stricter reporting and documentation requirements on transfer pricing arrangements.  The OECD recently published recommendations as part of its Base Erosion and Profit Shifting (“BEPS”) initiative and Vietnam have been quick to introduce many of these recommendations into local law, greatly increasing the documentation burden on multinationals.

Decree 20 and Circular 41, which came in to effect on 1 May 2017 and 28 April 2017 respectively, introduced country-by-country reporting and master file obligations in addition to existing requirements for a local file and the submission of an annual transfer pricing declaration form.

With the drive for transparency and aggressive transfer pricing tax audits here to stay, it is vital that documentation is both robust and consistent to offer the greatest chance of successfully dealing with tax audit challenges.

We work regularly with multinationals and leading Vietnamese groups to assist with transfer pricing compliance. We also perform risk reviews where we proactively identify exposures and recommend practical solutions; and assist our clients to resolve particularly complex and controversial transfer pricing matters and disputes.

We can help you with

  • All aspects of transfer pricing documentation and compliance requirements from annual transfer pricing returns through to local transfer pricing documentation, master file and country-by-country reporting requirements;
  • Assessing gaps in your current transfer pricing documentation; and
  • Preparing local and regional benchmarking studies.

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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

Annett Perschmann-Taubert

Annett Perschmann-Taubert

Tax Partner, PwC Vietnam

Tel: +84 28 3824 0113 Mobile: +84 903292489

Monika Mindszenti

Monika Mindszenti

Director, Transfer Pricing Services, PwC Vietnam

Tel: +84 24 3946 2246, Ext. 1506

Judith Henry

Judith Henry

Director, Transfer Pricing Services, PwC Vietnam

Tel: +84 28 3823 0796, Ext. 1525

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