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Jim Fuller

Sean Foley

Thuan Pham The Vietnamese tax authorities have conducted a number of tax audits focusing on transfer pricing abuses in recent years, including by companies with foreign investment. While no definitive judgments have been issued, several companies are suspected of having abused the transfer pricing regulations and committing tax evasion. In an effort to reduce tax evasion and tax fraud, and to achieve efficient tax governance, an amendment to the Law on Tax Governance was introduced on November 20 2012, along with the introduction of an advance pricing agreement (APA) programme, with the aim of providing taxpayers and tax authorities with tax certainty, transfer pricing planning, protection from tax evasion, and tax efficient management.

Brendan Brown

Hans Rudolf Habermacher

In part one of a two-part series, Richard Allen of Retailers Against VAT Avoidance Schemes (RAVAS) explores the avoidance debate in relation to low value consignment relief (LVCR), VAT and the offshore fulfilment industry.

Clint O’Connell When hiring labour in Cambodia, it is essential to know what kind of relationship exists from a tax perspective. Importantly, the General Department of Taxation (GDT) will not base its view simply on the contract or agreement in place, but on the actual facts of the matter. The method and rate of taxation varies for employees and independent contractors – employees will be subject to Tax on Salary (TOS), whereas contractor's fees will be subject to withholding tax. A resident will be subject to monthly deductions of tax withheld from salaries received from both Cambodian and foreign sources (in practice only Cambodian sourced salary can be declared). TOS rates are progressive, ending with a top marginal rate of 20% of the taxable base (see Table 1).

The OECD's Action Plan for tackling base erosion and profit shifting (BEPS) was unveiled on July 19 at the G20 meeting of finance ministers in Moscow. The plan discusses a timeframe of between 12 and 24 months for implementing action and outlines how the OECD will work with national states to improve the overall tax take and clamp down on tax arbitrage by addressing perceived flaws in international rules. The plan specifically references transfer pricing and Sophie Ashley discusses its impact on global principles and how taxpayers can expect them to change.

At the G8 summit in Northern Ireland in July leaders committed to a common set of principles that would limit profit shifting and increase tax transparency. Emma Powell looks at how achievable these aims are and what impact they will have on businesses.

Carolina Gonzalez Cortes