FREE: Vietnam revenue pledges to focus on transfer pricing deceptions

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

FREE: Vietnam revenue pledges to focus on transfer pricing deceptions

The Ho Chi Minh City Tax Department in Vietnam has promised to investigate global companies who claim to make consistent losses in the country.

vietnam150.png

In an interview with newspaper, Tuoi Tre, Le Thi Thu Huong, deputy director of the city’s revenue department said a business may establish two or three companies at the same time and then adjust the revenue to avoid paying tax.

One method companies use is to register an affiliate on the country’s stock exchange and then let other affiliates contribute profits to the listed one so it appears to be doing better than it is and pushes the share price up to deceive investors.

The revenue official said 15 out of 197 domestic firms that reported losses in 2010 are suspected of engaging in transfer pricing after inspection. Of these 15, she added, four will be followed closely.

Huong said the inspection has paid off so far, uncovering several domestic companies, which show signs of transfer pricing abuse, but it is difficult for the tax department because of the problems involved in confirming selling prices between these businesses and others internationally.

“The Finance Ministry’s Circular 66 currently is the base for transfer pricing fighting with five price calculation and comparison methods,” said Huong. “However, a tax officer finds it difficult to carry out the methods as he cannot base them on any independent data provider and has to survey and collect information from the market and related agencies. For FIEs [foreign invested enterprises], authorities should provide tax departments with policies in their home countries to make comparisons.”

The tax agency plans to focus its inspection on those businesses suspected of transfer pricing over the 2011 to 2015 period.

The loss-making companies still enjoy value-added tax refunds.

“They should be responsible for paying taxes to support development of the country where we operate, in addition to providing jobs for locals. This is a matter of business ethics for business people and FIEs,” Huong said.

more across site & shared bottom lb ros

More from across our site

Belt and Road Initiative countries face tax incentive conundrums due to pillar two, but relatively few countries would seek to scrap the project, ITR has heard
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping the GCC’s investment incentive landscape, shifting the region from rate-based competition toward substance-driven economic positioning
The acquisition of a two-partner practice from Stephenson Harwood means that Charles Russell Speechlys has the largest private client team in Asia, the firm claimed
Complex and constantly shifting rules on global mobility mean ‘the risk is too great’ for staff to work abroad on personal time, EY’s Maureen Flood tells ITR
While it’s great that the OECD is alive to multinationals’ fears of being caught in a compliance trap, the ‘common understanding’ illustrates a worrying lack of readiness
Rising demand for specialist expertise has fuelled the growth in tax partner headcounts, Cain Dwyer found; in other news, Switzerland has been urged to reconsider pillar two
An OECD report on the taxation of the digital economy is expected by the end of 2026, according to the group of nations
Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance
As demand for complex, cross-border private client counsel spikes, Patrick McCormick sees opportunity in starting from scratch
As part of an exclusive global alliance, KPMG will become one of Anthropic’s ‘preferred consultants’ for private equity
Gift this article