Category: Vietnam

Multinational conglomerates escape transfer-pricing charge

VietNamNet Bridge – The agreements on double taxation avoidance that Vietnam has signed with other countries is one of the reasons that have made it impossible for state agencies to clarify the suspected cases of multinational conglomerates conducting transfer pricing. A lot of multinational conglomerates such as Coca-Cola, Metro Cash… – Continue reading

Foreign-invested footwear manufacturers show their power

Footwear is one of the industries with high export turnover. However, the profitable industry is being controlled by companies from South Korea and Taiwan. According to the Vietnam Leather & Footwear Association (Lefaso), with 800 enterprises and 1 million workers, FIEs account for one-fourth of total number of footwear makers,… – Continue reading

An Overview of Transfer Pricing in Vietnam

Transfer pricing is a tax planning method where related companies enter into transactions among each other to shift funds, and thereby profits. For instance, a parent company can extract funds from a subsidiary by having the issue a dividend, but the parent can also provide a service to subsidiary and… – Continue reading

East Africa: New Reporting Code for Mncs Could Save Africa $35b

East African countries expect to collect more revenue under a new code drawn, by the world’s richest economies to stop foreign multinationals from dodging taxes in host countries. The new code — Base Erosion and Profit Shifting (BEPS) — adopted by G20 at its meeting in Turkey two weeks ago,… – Continue reading


Global taxpayers can expect to pay more tax in the years ahead. Many governments worldwide continue to update their tax legislation and expand their tax systems to repay debt and pay for increased social welfare, even as the memory of the last global financial crisis lingers. These are the conclusions… – Continue reading

KPMG leader visit highlights BEPS initiative

Latest developments under the Base Erosion and Profit Shifting (BEPS) initiative of the Organisation for Economic Co-operation and Development (OECD) was one of the key points of a recent four-day visit by KPMG’s global leader for Transfer Pricing Services Sean Foley to Vietnam. He shared the issue with Vietnam’s General… – Continue reading

Finance Ministry addresses against transfer pricing force

The Ministry of Finance yesterday announced establishment of Transfer Pricing Inspection Agency under the Inspection Department of the General Taxation Department. This aims to fight against complicating transfer pricing which has resulted in budget revenue’s losses. The agency will act as a counselor for the Taxation General Department to work… – Continue reading

NBR to sign deal with Bhutan to avoid double taxation

Bangladesh is set to sign an agreement with Bhutan to avoid double taxation to boost investments, trade and facilitate information exchange between the two Saarc nations, the National Board of Revenue said in a statement. A team led by NBR Chairman Md Nojibur Rahman is now in Thimpu to take… – Continue reading

Transnational laws needed to curb fires

To solve the problem of the haze afflicting Singapore, Indonesia and Malaysia, extraterritorial action is needed to quench the forest fires in Indonesia that are generating the haze. A cross-border solution is a necessary answer even if it raises questions of national sovereignty. The Singapore Government should implement laws that… – Continue reading

There is no evidence of Coca-Cola transfer pricing: Minister

VietNamNet Bridge – Minister of Planning and Investment Bui Quang Vinh has disagreed with the opinion that Coca-Cola has been conducting transfer pricing in Vietnam, affirming that the soft drink manufacturer is innocent until proven guilty. Vinh made the statement at the Vietnam Global Investment Forum held in Hanoi in… – Continue reading

Cabinet okays amendments to tax avoidance pacts with Israel, Vietnam

NEW DELHI, OCTOBER 7: The Union Cabinet on Wednesday gave its nod for the introduction of a ‘limitation of benefit’ clause in the double taxation avoidance convention (DTAC) with Israel. The ‘LOB’ Article is an anti-abuse provision aimed at preventing misuse of the convention. The protocol that received the Cabinet’s… – Continue reading


Bloomberg BNA’s first transfer pricing conference in Asia—the latest offering in our Global Transfer Pricing Conference series with Baker & McKenzie—could not have been better timed. The day the conference opened, Sept. 17, China issued a revised draft circular on transfer pricing that completely changed the game for multinational companies… – Continue reading

Vietnam-US double taxation avoidance will bring more gains than losses

With the agreement with the US, Vietnam has now signed the double taxation avoidance agreements with 70 out of 170 countries and territories with which Vietnam has trade and investment relations. Double taxation is considered a barrier to trade and investment. It discourages transnational investments while prompts individuals and businesses… – Continue reading

British Teachers Abroad Have One Last Chance to Avoid UK Taxes on Their Pension

QROPS specialists are offering free transfers to Gibraltar QROPS for August only for teachers who want to retire abroad and avoid all UK taxes and future UK taxes on their existing teacher’s pension scheme. This is the final chance for teachers living abroad to transfer their UK pensions outside the… – Continue reading

New circular introduces key corporate-income tax changes

On June 22, 2015, the finance ministry issued Circular 96/2015/TT-BTC, guiding the corporate income tax regime in Decree 12/2015/ND-CP (“Decree 12”) of the government, dated February 12, 2015. Decree 12 provides the details for the implementation of the law that amends and supplements some articles of tax laws, tax decrees… – Continue reading

Khalifa ratifies UAE agreements

ABU DHABI: President His Highness Sheikh Khalifa Bin Zayed Al Nahyan has issued a number of federal decrees with respect to ratifying agreements between the UAE and a number of friendly countries and transferring, appointing and promoting a group of diplomatic corps members. The decrees have been published in the… – Continue reading

Double taxation in the AEC and tax credits in Thailand

The long-awaited formation of the Asean Economic Community (AEC) is just over five months away. Drawn by the promise of a freer flow of goods, services, investment, capital and skilled labour, many businesses need to study how to prevent or reduce the effects of double taxation. Double taxation results from… – Continue reading

Vietnam: FIRST EVER Double Taxation Agreement Signed Between Vietnam And The United States Of America

On 07th July 2015, the United States and Vietnam signed an income tax treaty with Vietnam, the first ever between the two countries. The Double Taxation Agreement applies to personal income tax and enterprise income tax in the case of Vietnam. What is a permanent establishment? Under the Double Taxation… – Continue reading

Vietnam: Refinancing A Domestic Loan With An Offshore Loan?

Vietnamese regulations and policy are certainly not in favor of using foreign loans to refinance existing domestic loan debts. However, the State Bank of Vietnam (SBV) could feasibly exercise its discretion to permit such loans if applicants made a compelling case. Prudent cross-border lenders will require Vietnam borrowers to disclose… – Continue reading

New transfer pricing law aims to counter tax planning

Tax avoidance can be defined as aggressive tax-planning strategies and structures by multinational companies that take advantage of the gaps or mismatches in tax rules to shift profits to low-tax locations. While many countries around the world have either general or specific anti-avoidance legislation to tackle this problem, the current… – Continue reading

Foreign-invested businesses top all others in 2014 social insurance debt in Vietnam: report

Foreign-invested enterprises (FIEs) and foreign organizations last year topped all other economic sectors of Vietnam’s economy in social insurance debt with over VND2.13 trillion (US$97.9 million), according to a government report on the management and use of social insurance funds in 2014. This was a staggering 192.5 percent year-on-year surge,… – Continue reading

Vietnam: Contract Manufacturing And Tolling Agreements

I. VAT and Customs In many cases, the principal in the contract manufacturing relationship owns some or all of the raw materials, work-in-process and finished goods throughout the manufacturing process. The principal and many of the suppliers are typically outside of the manufacturing jurisdiction. 1. Generally Speaking, What Are The… – Continue reading

Transfer pricing: the other side of the FDI coin

VietNamNet Bridge – How to deal with transfer pricing – whether to view it as an inevitable part of foreign direct investment (FDI) or take drastic measures to stop it – remains a controversial matter among Vietnamese. METRO Cash & Carry Vietnam (MCC) will have to pay VND507 billion (US$23.8… – Continue reading

Metro’s transfer pricing practices unmasked by GDT

VietNamNet Bridge – Metro Cash & Carry Vietnam, the German invested retailer, which repeatedly reported losses over the last 12 years in Vietnam, has engaged in transfer pricing to evade tax, according to the General Department of Taxation (GDT). It has asked the big retailer to reduce the reported loss… – Continue reading

Countries and Companies Square Off Over International Tax

An OECD initiative on tax evasion is causing ripples around the world While a host of topics — from the necessity and the proposed scope of corporate tax reform, to corporate rate reduction and corporate inversions — are of major concern to those engaged in international tax, the overriding issue… – Continue reading

The Cost of Business in Myanmar Compared With China

Myanmar remains an enigmatic country – one of the largest and most populated in Asia but also one of its poorest and least understood. It remains a country that has largely stood still for seventy years – hardly any infrastructure of note was developed in the country since the end… – Continue reading

Metro Vietnam found owing over $23.6mn in tax in transfer pricing inspection

The Vietnamese unit of Germany’s Metro Cash & Carry will have to pay almost US$24 million in tax arrears after its wrongdoings have been unearthed in a transfer pricing inspection that concluded Monday. Metro Cash & Carry Vietnam Co. Ltd. began coming under scrutiny on suspicions of transfer pricing in… – Continue reading

Tax inspectors find $23.7 mln worth of violations at Metro Cash & Carry

Vietnamese tax inspectors have found multiple violations at the local subsidiary of German retail giant Metro, estimating them to be worth VND507 billion (US$23.7 million). Of the total amount, Metro Cash & Carry Vietnam was ordered to immediately pay VND62 billion ($2.8 million) in arrears of income taxes for its… – Continue reading

Letter – Immigration reform needs a restart button

Advertisement A false image depicts undocumented immigrants as criminals because they entered the United States illegally and received many government benefits. Wars in Korea, Vietnam, Afghanistan and Iraq created labor shortages. Some industrial complexes and corporate agriculture used growing numbers of undocumented laborers to whom they paid less than minimum… – Continue reading

Vietnam – FATCA reporting guidance

April 2: Guidance from the State Bank of Vietnam provides financial institutions and branches an automatic 90-day extension of time in which to file their FATCA reporting forms. Therefore, financial institutions have until 30 June 2015 to file their FATCA reports to the U.S. tax agency (IRS). KPMG observation Pending… – Continue reading

Charting the Limits of Acceptable Tax Planning in Singapore

In 2015, Singapore celebrates its 50th year of independence and also mourns the passing of its first Prime Minister Lee Kuan Yew who steered Singapore’s success for many critical years. From its origins as a British trading post in 1819, Singapore has grown into one of the busiest ports and… – Continue reading