Comprehensive transfer pricing – 15 Asia Pacific countries – 400 pages: Australia, China, Hong Kong, India, Indonesia, Japan, Malaysia, New Zealand, Philippines, Singapore, South Korea, Sri Lanka, Taiwan, Thailand, Vietnam.
Transfer Pricing ASIA
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Transfer Pricing Asia Overview

Transfer Pricing Asia
Robert Feinschreiber, Esq.
Attorney and Counselor
Margaret Kent, Esq.
Attorney and Counselor
TransferPricingConsortium.com

Vietnam Transfer Pricing

The Vietnamese tax authorities have the most expansive view of related-party ownership compared with other countries in Asia, including twenty percent shareholding and dominating the other party by controlling its output or by controlling its supplies.

The taxpayer must apply the “most appropriate” transfer pricing method. The taxpayer must make use of comparables data and benchmarking

The Vietnamese tax authorities have wide power to challege taxpayers, including documentation, underpayment, tax evasion, and fraud. The Vietnamese tax authorities impose strong penalties on taxpayers for failure to comply with their tax regime. The penalty can amount to one to three times the amount of the tax liability adjustment if the government ascertains that the taxpayer’s tax practice is abusive.

Vietnam provides strict deductions for expenses, provides revenue / expense matching, caps deductions for interest and for marketing expenses, and reject deductions for intercompany services fees. Taxpayers are most vulnerable to tax audits when their tax holiday ends. Hot button issues include permanent establishment issues and using offshore jurisdictions to reduce taxation.


Feinschreiber & Associates
Robert Feinschreiber & Margaret Kent

1121 Crandon Blvd. F301
Key Biscayne, FL 33149
Primary Phone: 305.361.5800
or 305.505.9200
Fax: 305.365.2276
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www.transferpricingconsortium.com
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