Our March 2018 Tax Update publication looks at Transfer Pricing obligations as we approach year-end submission deadlines, and we also look at a selection of recent Official Letters released by Tax and related authorities.


Following the release of Transfer Pricing Decree 20/2017/ND-CP in 2017, taxpayers in Vietnam are subject to additional requirements when finalising their 2017 Corporate Income Tax (“CIT”) obligations. For most taxpayers, their 2017 finalisation is due by 31 March 2018 (90 days from year end).

When finalising 2017 CIT obligations, taxpayers need to submit a Transfer Pricing Declaration Form (“Form 1”) together with their CIT finalisation return. Unless exempted, taxpayers must also prepare up to 3 additional forms (detailed below).

Exemptions from completing these additional forms apply to taxpayers which;
1) Have total revenue less than VND 50 billion, and total related party transactions less than VND 20 billion, or
2) Have an Advanced Pricing Agreement in place with the authorities, or
3) Have total revenue less than VND 200 billion, undertake “simple” activities, and meet one
of the following profit ratios (before interest and tax) on their revenue:
a) 5% for distribution activities
b) 10% for manufacturing activities, or
c) 15% for processing activities

The three additional forms that are required to be submitted are:
1) Form 2, detailing the required information that is being maintained in a Local File for the Vietnamese entity
2) Form 3, detailing the required information that is being maintained in a Master File and that all the required information is being contained therein, and
3) Form 4, is for the Country by Country Report (for those companies with consolidated global revenue exceeding VND 18 trillion).

For more information, click Vietnam Tax Update March 2018 – Domicile


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