The reform intends to modernise the transfer pricing regime beyond the review of contractual arrangements, to an analysis of the substance linked to value creation.
One of the intentions of MoF is to adopt and implement the Organization for Economic Cooperation and Develop ment’s (OECD) base erosion profit shifting (BEPS) recommendations on transfer pricing (TP) as they are relevant to Vietnam, with the release of the latest version of the draft TP decree on October 26, 2016. This decree will also aim to prevent the loss of tax revenue, so diligent enforcement is expected once approved before the end of the year, with potential effect from January 1, 2017.
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