TRANSFER PRICING SERVICES
Transfer pricing services are becoming increasingly common, especially in the context of the rapid growth of multinational corporations and foreign-invested enterprises operating in Vietnam. Understanding the rising demand for these services, MAN provides reputable transfer pricing consulting and associated transaction documentation services, ranking among the leading providers in Vietnam.
1. What are transfer pricing services?
Transfer pricing services refer to supporting businesses in preparing a Transfer Pricing Documentation (TPD) for related-party transactions. This documentation plays a crucial role for organizations that engage in related-party dealings and are required to submit it to tax authorities.
In addition, transfer pricing risks occur when businesses involved in related-party transactions, either domestically or internationally, determine internal prices for goods, services, tangible and intangible assets, loans, or financial services between affiliates. Transfer pricing risks may result in negative consequences such as:
✈ Loss of taxable income and tax obligations due to profit shifting to low-tax or zero-tax jurisdictions
✈ Inspections, penalties, tax arrears, and interest charges imposed for non-compliance with transfer pricing regulations
✈ Disputes, litigation, reputational damage, and loss of trust with regulators, partners, and the public
A complete Transfer Pricing Documentation must include:
✈ All information relating to affiliated transactions
✈ Corporate structure and operational diagram
✈ Details of related-party transactions arising during the reporting period
✈ Information on comparable independent transactions
✈ Transfer pricing services assist businesses in preparing Transfer Pricing Documentation for related-party transactions
2. Common methods of transfer pricing used by businesses
Transfer pricing methods allow enterprises to maximize profit allocation through loss shifting or profit shifting. Currently, six common transfer pricing techniques used by FDI and foreign-invested enterprises include:
✈ Increasing the value of contributed assets (such as land use rights, equipment, technology, machinery, etc.)
✈ Raising input material costs for production while reducing selling prices to affiliated companies
✈ Transfer pricing via technology and brand licensing
✈ Financial transfer pricing
✈ Increasing management and administrative service fees
✈ Using intermediary companies to issue revised or recreated invoices
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3. Which businesses will be subject to tax inspections and audits in the coming period?
According to Official Dispatch No. 12454/BTC-TTr issued by the Ministry of Finance on 29/10/2021 regarding the financial inspection and audit plan for 2022, priority will be given to enterprises falling under the following categories:
✈ Businesses with high tax risks
✈ Enterprises receiving tax exemptions or reductions
✈ Businesses conducting project, brand, or capital transfers
✈ Enterprises operating in new or specialized business sectors
✈ Organizations in finance and banking
✈ Foreign-invested businesses engaging in transfer pricing
✈ Importers of high-value and high-tariff goods
✈ Enterprises importing materials for outsourcing or export-oriented production
✈ Export processing enterprises
✈ Businesses operating on digital platforms and e-commerce
=>>> These are the groups prioritized for tax inspection and audit.
4. MAN’s transfer pricing and related-party transaction reporting services
MAN provides the following transfer pricing services:
✈ Preparation of Related-Party Transaction Reports - Transfer Pricing Reports
✈ Consultancy for preparing Transfer Pricing Documentation
✈ Review of Related-Party Transaction Documentation and Transfer Pricing Files
✈ Representation and support during transfer pricing inspections
✈ MAN provides comprehensive support for Transfer Pricing Reporting - Related-Party Transaction Reporting.
5. What makes MAN different?
Strengths of MAN’s transfer pricing documentation services:
✈ A team of highly qualified experts specializing in transfer pricing consulting, offering optimal and highly practical solutions
✈ Transfer pricing specialists at MAN handle diverse industries and business models, ensuring strategies tailored to each client
✈ We support businesses in minimizing risks from tax inspection authorities and optimizing tax efficiency
✈ MAN accompanies enterprises throughout the entire transfer pricing process
6. MAN’s commitment to clients
We commit to:
✈ Strict compliance with transfer pricing regulations and effective risk control in related-party transactions
✈ Absolute accuracy in every recorded transaction
✈ Continuous support in resolving potential errors
✈ Guaranteed on-schedule completion of all client requirements
As demand for transfer pricing services continues to grow, MAN remains one of the most reputable, professional, and trusted service providers in the market. For further consultation, please contact our HOTLINE.