(Tax management of transfer pricing)

2017 marks the breakthrough in determining market price of affiliate transaction in Vietnam. The Vietnamese government assigned the Ministry of Finance to create tax reforms and update current tax regulations, in consideration of the Base Erosion and Profit Shifting (BEPS) project suggested by the Organisation for Economic Co-operation and Development (OECD).

In this context, the government issued Decree no. 20/2017/NĐ-CP on 24th of February 2017 regulating principals, methods to identify affiliate transaction; taxpayer’s duty in declaration, determining affiliate transaction price and tax declaration; state management duties of taxpayers involving in affiliate transaction. The Decree is effective from 1st May 2017.

On 28th April 2017, the Ministry of Finance issued Circular no. 41/2017/TT-BTC. This Circular instructs those who the Decree no. 20/2017/NĐ-CP applies to implement the regulations of analysis, comparison, selection and determining price of affiliate transaction, making supporting documents of affliate transaction price, and applying regulations of exempting affiliate transaction price documentation as per Decree 20/2017/NĐ-CP.


  1. Consultant service on identifying affiliate relations
  • We help you determine whether or not your affiliate relations are governed by the laws.

  1. Service of consulting and making affiliate transaction declaration form

We consult and help to make affiliate transaction documents under 2 cases:

    • Corporate is partially exempt from making declaration (exempt from Part III, IV)
    • Corporate declares as per Form 01 and is exempt from making affiliate transaction price documents.
  1. Service of consulting and making affiliate transaction documents

We consult and support corporates to prepare affiliate transaction documents, including:

    • National documents;
    • Global group information documents;
    • International profit report.
  1. Service of consulting and explaining to transfer pricing inspectors

Service includes:

    • Consult on working with tax department.
    • Review and analyze risks and opportunities for transfer pricing.
    • Advocate documents in the event of transfer pricing inspection.

Contact us for Affiliate Transaction consultant (Transfer Pricing consultant)

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