Transfer Pricing Service
Current Vietnamese statutory on the transfer pricing
Enterprises having business transactions with associated parties are obliged to prepare and submit the Report of Information about Related-Party Relationsship and Transaction, the deadline for submission of this report is also the deadline for submission of the enterprise income tax finalization declaration.
Forms of Related-Party Relationsship and Transaction
| For fiscal years 2005 -2016 | For fiscal years from 2017 |
| Form No. GCN-01/TNDN (2015-2009)
Form No.: GCN-01/QL(2010-2013) Form No.: 03-7/TNDN (2014-2016) |
Form No. 01: Related-Party Relationsship and Transaction
Form No. 02: The transfer pricing documentation package – Local file Form No. 03: The transfer pricing documentation package – Master file Form No. 04: Country-by-Country report of an ultimate parent company |
Requirements of keeping and provision of information, documents and source documents
Enterprises having associated transactions shall have the obligation as well as responsibility to store and produce information, documents and evidence already used as grounds for the application of methods or determining the market price of products in such associated transactions at the request of tax offices when conducting examination or inspection. Information, documents and evidence related to production and business activities and methods of determining market prices of associated transactions must be established at the time of arising of associated transaction, updated and supplemented throughout the time of performance of the transactions and preserved under the provisions of the accounting, statistics and tax laws regarding preservation of accounting vouchers and books. Enterprise shall be obliged to prepare a file including the following information, documents and source documents relating to a related transaction:
| For fiscal years 2010-2016: | For fiscal years from 2017 |
| · Company’s general information.
· Company’s related party transactions. · Comapnay’s transfer pricing method. |
· Company’s general information.
· Company’s related party transactions. · Comapnay’s transfer pricing method. · Group’s organization structure. · Group’s business activities. · Group’s intangible assets. · Group’s financial activities. · Group’s business results and tax positions. |
DFK Vietnam service
- Prepare the annual report of Information about Related-Party Relationsship and Transaction.
- Transfer pricing documentation
- Provide market range of profit indicators
- Support enterprise in dealing with tax audit and dispute resolution.
- Apply for Advance Pricing Arrangements
Our commitment
We are a leading auditing firm in the field of providing transfer pricing services. Since the birth of the Vietnamese regulation on the transfer pricing in 2005, we have supported many foreign companies operating in Vietnam preparing the defensible documentation and dealing with tax audit.
We have the global presence over 85 countries, resources and industry expertise necessary to support the transfer pricing needs of the largest multinational companies.
Referernce:
– Circular No. 117/2005/TT-BTC dated 19/12/2005 effective for fisacl years from 2005 to 2009.
– Circular No. 66/2010/TT-BTC dated 22/4/2010 effective fro fiscal years from 2010 to 2016.
– Circular No. 41/2017/TT-BTC dated 28/4/2017 effective for fiscal years from 2017.
Send your inquiry of audit service: dfk@dfkvietnam.com