Transfer Pricing
(TP) Services
SERVICE DELIVERY PROCESS
STEP 1: Client Assessment and Service Engagement
The information to be collected from the client includes:
1. Enterprise Registration Certificate
2. Investment Registration Certificate
3. Financial Statements
4. Corporate Income Tax (CIT) Returns
5. Related-Party Relationship Structure / Organizational Chart
6. Summary of Related-Party Transactions Incurred
STEP 2: Service Fee Quotation and Contract Execution
SCOPE OF WORK |
SERVICE |
SERVICES FEES (VNĐ) Exclusive of VAT |
|---|---|---|
1 |
Preparation of Transfer Pricing Disclosure Appendices for the fiscal year… |
xx.000.000 |
2 |
Preparation of Country-Specific Documentation (Local File) for the fiscal year… |
|
3 |
Preparation of Global Transfer Pricing Documentation (Master File) for the fiscal year… |
|
4 |
Ongoing Transfer Pricing Advisory Services |
Ancillary service, no additional charge |
5 |
Support during Transfer Pricing Audits and Inspections (including preparation of explanations for submission to tax authorities, review and preparation of documents requested by the tax audit team) |
|
6 |
Direct liaison with tax authorities during on-site tax audits at the client’s premises |
xx.000.000 |
STEP 3: Development of a Service Implementation Plan Tailored to the Client’s Specific Circumstances
STEP 4: Service Execution
TRANSFER PRICING REGULATIONS IN VIETNAM
Concept
Transfer pricing refers to the allocation of income and/or expenses through commercial transactions between related parties within a group (“Related-Party Transactions – RPTs”) for the following purposes:
1. To take advantage of differences in tax rates and tax incentives;
2. To reduce tax liabilities and maximize the overall profit of the group.
Non-Compliance Behaviors and Penalties
– Late payment interest: 0.03% per day
– Incorrect tax declaration: Penalty equal to 20% of the additional tax assessed
– Tax evasion: Penalty ranging from 1 to 3 times the amount of tax evaded
High-Risk Taxpayer Groups for TP Audits
– Enterprises that have not fully complied with annual tax compliance obligations
– Enterprises with significant related-party transactions and/or substantial fluctuations in revenue (sharp decline or losses)
– Enterprises engaging in specific related-party service transactions (e.g. management fees, royalty fees, technical support services)
– Enterprises that have not been subject to tax audits or inspections for a long period
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