Transfer pricing services

In many countries in general and Vietnam in particular, transnational related party transactions between affiliates tend to increase in both quantity and form. With that trend, the competent authorities are addressing issues from transfer pricing and base erosion by completing the legal basis for related party’s transactions requirements as well as executing stricter requirements for tax filing in both substance and form. They also impose several penalties for violations.

For enterprises that have transactions with affiliates, especially foreign direct investment (FDI), non-compliance with the requirements for submission of declarations and explanatory files may lead to the risk of being re-evaluated of transaction prices or taxable profits along with penalties and interest for late payment. These adjustments could also lead to greater consequences in terms of altered tax returns as well as negative media promotion.

Accordingly, the need to ensure full compliance with reporting obligations and to plan an effective transfer pricing strategy for the business' purposes is higher than ever.

Therefore, with a team of experienced transfer pricing consultants, we are ready to assist businesses in preparing transfer pricing documents and consulting transfer pricing with the following issues:

• Support enterprises to comply with tax regulations and determine transaction prices;

• Provide enterprises with important tools to reduce time and resources when addressing tax authorities' questions during tax inspection;

• Support enterprises to reduce the penalties which may be applied in case the tax authority fixes the transaction price that the enterprise has determined and;

• Strengthen the company's internal controls for compliance with the arm’s length principle, including early identification of necessary adjustments and tax planning and transaction pricing opportunities.

Our services include:

• Fulfilling compliance obligations (prepare transaction pricing documentations including Local file, Master file, and country-by-country report and related-party transaction declarations);

• Prepare/Review supporting documents and policies related to transaction price determination;

• Execute the plannings and restructurings related to transaction price determination;

• Support to negotiate the case of enterprises being checked on determining transaction prices;

• Update regulations on transfer pricing in related–party transactions