As the global economy becomes more integrated, nations are more engaged in effective ways to protect their tax bases. The Vietnamese authorities are increasing tax audit/ inspection frequency as well as supervising compliance on transfer pricing matters, especially for FDIs who have carried losses forward or had low profit margins for many years. The authorities continued to develop and improve transfer pricing regulations through various Decrees, Circulars since 2005 and Decree No. 132/2020/ NĐ-CP, Decree No. 20/2025/NĐ-CP for enterprises engaging in related-party transactions.

Russell Bedford KTC’s Transfer Pricing Services team has the experience and also supported by a network of global transfer pricing specialists from Russell Bedford member firms around the world and from our associated experts in the field, especially from our Russell Bedford Hongkong and Russell Bedford Malaysia. This helps us look beyond borders and understand the uances of different ational tax regulations.

In addition, our local tax experts’ strong understanding of the Vietnamese regulations & compliance procedures (including Tax audit & inspection), could provide great assistance in working/ negotiating with the Tax authorities.

Our transfer pricing services include:

• Risk assessment reviews.
• Documentation and Compliance services,
• Audit defense advice,
• Advisory on Advance Pricing Agreements – APA;
• Competent authority procedures and Transfer pricing planning