KPMG Transfer Pricing Alert - Circular 45 on APA
June 2021 | KPMG in Vietnam
The Ministry of Finance issued Circular No. 45/2021/TT-BTC (“Circular 45”) to provide further guidance on the administration of the Advance Pricing Agreement (“APA”) program in accordance with the Tax Administration Law and Decree 126/2020/ND-CP (“Decree 126”) (effective from 5 December 2020). Circular 45 replaces Circular 201/2013/TT-BTC (“Circular 201”) and takes effect from 3rd August 2021. KPMG hereby would like to provide some insights and recommendations from a professional perspective.
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