Addressing Transfer Pricing & Business Structuring | KPMG | VN
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BEPS Decree: Addressing Transfer Pricing and Business Structuring

The year 2016 marks a major watershed in the state of affairs related to transfer pricing in Vietnam...

10 January 2017, 8:30AM - 11:00AM, ICT Ho Chi Minh City (Saigon), Viet Nam

The year 2016 marks a major watershed in the state of affairs related to transfer pricing in Vietnam, with a visible upcoming tax reform announced by Ministry of Finance (MOF) to introduce regulatory changes to tackle Base Erosion Profit Shifting (BEPS) practices in connection with multinationals’ transactions and their transfer pricing.

The Decree on of transfer pricing introduces a number of rules such as the substance over form principle, the arm’s length requirement, guidance for treatment of tax deduction of inter-group service fees and inter-company loan interest expenses, considerations for intangible assets; together with new reporting and documentation requirements re-examining transfer pricing documentation, such as Master file, Local file, and country-by-country reporting in line with BEPS Action 13. The Decree is understood to aim at prevention against State budget loss and protection of Vietnam’s fair share of tax.

For many multinationals, this will be a significant and fundamental change from their conventional transfer pricing practices in Vietnam, and they should be prepared to review and revise their transfer pricing policies, strategy, and even the global business structure including Vietnam, to navigate the contemporary tax framework in the country.

The presentation will provide a comparative view of BEPS legislation across the different countries including the US, EU, Asia Pacific, and details on potential impacts from the new regulations for Vietnam-based firms/companies and overseas companies that have business transactions with Vietnam-based entities, and high-level recommendations to better manage the Decree once it comes into effect.

The presentation will be made by Mr. Hoang Thuy Duong – Partner in charge of Integrated International Tax of KPMG in Vietnam who has worked with multinationals and Vietnam’s fiscal authorities since the inception of the country’s transfer pricing regime and application of BEPS to Vietnam, including the in-depth and substantive engagements with the Ministry of Finance’s policies makers in relation to the Decree and Advance Pricing Arrangements.


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8:30am             Registration

9:00am             Welcome, Introductions

9:05am             Presentation: BEPS Decree: Addressing Transfer Pricing and Business Structuring

10:00am           Round-table Discussion

10:30am           Wrap-up & Closing remark


Closing Registration

Many thanks for your interest in our events and look forwards to welcoming you soon in upcoming KPMG events.

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