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 2025

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

The UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget
Awards
The firms picked up five major awards between them at a gala ceremony held at New York’s prestigious Metropolitan Club
The streaming company’s operating income was $400m below expectations following the dispute; in other news, the OECD has released updates for 25 TP country profiles
Software company Oracle has won the right to have its A$250m dispute with the ATO stayed, paving the way for a mutual agreement procedure
If the US doesn't participate in pillar two then global consensus on the project can’t be a reality, tax academic René Matteotti also suggests
If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues
As World Tax unveils its much-anticipated rankings for 2026, we focus on EMEA’s top performers in the first of three regional analyses
Firms are spending serious money to expand their tax advisory practices internationally – this proves that the tax practice is no mere sideshow
The controversial deal would ‘preserve the gains achieved under pillar two’, the OECD said; in other news, HMRC outlined its approach to dealing with ‘harmful’ tax advisers
Former EY and Deloitte tax specialists will staff the new operation, which provides the firm with new offices in Tokyo and Osaka
Gift this article