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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.