Transfer Pricing Services

Our Tax professionals can maximize your earnings by combining a comprehensive knowledge of tax regulations and the capacity to well plan and well prepare to minimize tax risks as well as reduce your tax bills…

What are the transfer pricing files?

When taxpayers having related party transactions, taxpayers shall be responsible for retaining and providing the transfer pricing files comprising information, documents, data and records, including:

• Interrelationship and related party transaction information provided in the form given in Appendix I of the Decree 132/2020/NĐ-CP dated 5 November 2020 (“Decree 132”);
• Local files, including information about transfer pricing, transfer pricing policies and; methods, prepared and deposited at taxpayers’ offices according to the directory of information and documents prescribed in Appendix II of Decree 132;
• Master files containing information about business activities of multinational groups, transfer pricing policies and methods of global groups and policies on allocation of income and decentralization of operations and functions in value chains of groups according to the directory of information and documents prescribed in Appendix III of Decree 132;
• Country-by-Country reports of profits of ultimate parent companies prescribed in clause 5 and Appendix IV of Decree 132.

Why do the companies have to prepare the transfer pricing files?

Tax authorities shall be vested with authority to set the levels of price, profit margins or profit split ratios; levels of taxable income or corporate income tax payable for any taxpayer failing to comply with transfer pricing declaration or determination requirements; failing to provide or incompletely provide data and information provided for the purpose of determination of prices of related party transaction. So, it is compulsory for a company having related party transactions to prepare and maintain transfer pricing files.

Our transfer pricing services

We will be able to explore the transfer pricing arrangements between the Company and its related parties, which are deemed consistent with Vietnam’s transfer pricing rules, our deliverables to you under this services including: 

• A Local file in English and Vietnamese; and
• A Cover Letter for TP Report in English and Vietnamese;Form No. 01: Information about related-party relationships and transactions;
• Form No. 02: List of required information and documents in the local file;
• Form No. 03: List of required information and documents in the global master file;
• Explanation letter for Form No.04: Declaration of information in the country-by-country report.
• Preparation or Review and translation of Master File;

Why choose us for transfer pricing services

With more than ten (10) years providing services in Vietnam, our partner and staff have a long time practicing in tax services with a brilliant combination of local experiences and global knowledge. We can help you overcome your challenges:

• Staffing shortage and lack of expertise;
• Insufficient working practices and approach;
• Excessive costs and lack of efficiency.

Then, we can create a value to you by:

• Select appropriate method(s) to be used to test the Company’s related party transaction;
• Prepare the transfer pricing file in the most clearly structure to be accepted by the Tax Authority;

Dealing with tax authorities

The final tax position may be subject to review and investigation by a number of authorities, who are enabled by law to impose severe fines, penalties and interest charges and dealing with the tax authorities can be a daunting task. We have developed a strong relationship with the General Department of Taxation and local Tax Office personnel. We are comfortable in dealing with the tax authorities on your behalf to handle your transfer pricing concerns.

In relation to transfer pricing services, our approach will include the followings:

Information request

• Provide list of requested information/documents for the Company’s preparation;
• Interview and collect information on the Company’s functions, assets, risks and related party transactions.

Industry analysis

• Analyze the industry which the Company is operating in.

Inter-company transactions

• Document the Company’s related party transactions and the pricing policies applied in such transactions during the year under study.

Function and risk analysis

• Analyze the function and risk in relation to transactions with related parties of the Company during the year under study.

Selection of TP method

• Select appropriate method(s) to be used to test the Company’s related party transaction.

Application of TP method (Comparability analysis)

• Applies the selected method(s) to assess the arm’s length nature of the Company’s pricing policy applied in related party transactions.

Economic analysis

• Documents, evaluates, and analyzes the results of the entities’ business performance, including related party transactions.

Draft and finalization of the Local file

• Assist in drafting Local file in terms of industry analysis, functional analysis, related party transactions, and financial analysis.
• Assist to select TP methodology: analyzes the transfer pricing methods and summarizes the selection of an appropriate method(s) to be used to test the reviewed related party transactions;
• Assist in preparation of the Benchmarking Study (“BMS”) which had been conducted on an entity-wide basis for the Company’s operating business result in the reviewed period; and
• Provide a draft Local file to the Company for your comments and finalize the Local file upon your approval.

Preparation or Review and translation of Master File.

Contact us 

Nguyen Ba Chinh 

Mac, CPA (Aust.), CPA (Vietnam), CPTA
Managing Director
E: nguyen.chinh@rtasean.com
HP: +84 904 917 259
Tel: +84 24 6666 6860
Fax: +84 24 6666 6859
Add: Floor 3 | Stellar Garden | No. 35, Le Van Thiem street | Thanh Xuan dist | Hanoi | Vietnam