Global

Details

  • Service: Tax, International Corporate Tax, Global Transfer Pricing Services, Global Compliance Management Services
  • Type: Regulatory update
  • Date: 6/5/2012

Vietnam - Plan targets 20% of tax audits also for transfer pricing audit 

June 5:  The Ministry of Finance released guidance approving an action plan for transfer pricing management for the period 2012-2015.  Decision 1250/QD-BTC (21 May 2012)

Under Decision 1250, the General Department of Taxation will primarily be responsible for organization and implementation of the transfer pricing action plan.


The action plan—while allegedly not intended to create an aggressive transfer pricing / tax regime for inbound investment—focuses on transfer pricing audits and “abusive” transfer pricing practices, and will build an advance pricing agreement (APA) system. Under the action plan, there are five key elements:


  • Transfer pricing audits in 20% of annual tax audits / inspections at both the central and provincial levels, with a transfer pricing audit manual to be developed
  • Enhanced transfer pricing regulations introducing specific guidance on managing abusive transfer pricing practices
  • Enhanced capacity of transfer pricing examiners, building on practical audit experience and international practice
  • Creation of a database of companies operating in “high” transfer pricing risk sectors and of prices for certain products
  • Coordination among government ministries and international cooperation with foreign tax authorities

To read a June 2012 report, prepared by the KPMG member firm in Vietnam: Transfer Pricing Alert (June 2012) (PDF 584 KB)




©2012 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.


The KPMG logo and name are trademarks of KPMG International.


KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.


The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.


Direct comments, including requests for subscriptions, to go-fmtaxnewsflash@kpmg.com.
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.

 

Share this

Share this

Subscribe

Subscribe to receive the latest TaxNewsFlash email alerts (you must select the option for TaxNewsFlash)


Already a Subscriber? Login


Not a member? Subscribe now

Contact us