MINISTRY OF FINANCE SOCIALIST REPUBLIC OF VIETNAM

GENERAL DEPARTMENT OF Independence – Free dom – Happiness

TAXATION Hanoi, Dec 13, 2023
No: 5654/TCT-TTKT
Regarding strengthening tax management for
businesses with associated transactions

Dear
- Tax Department of provinces and central cities
- Large Enterprise tax department

Notes:

● The document is issued by the General Department of Taxation and directed to

Tax Departments for implementation.

Problem: Increasing integration and globalization lead to businesses potentially manipulating

"transfer pricing" (intra-company pricing) to avoid corporate income tax, causing revenue loss
for the government and unfair competition.

The General Department of Taxation requests the Tax Department to do the following things

● Increased Tax Inspection:

○ Focus on businesses with high transfer pricing risks (unusual income/expense,
losses with expansion, low tax burden).
○ Identify these businesses through data analysis and in-depth investigations.
○ Include them in 2024 inspection plans with specific focus on transfer pricing.
● Collaboration and Information Sharing:
○ Educate businesses about relevant tax laws and policies.
○ Increase information exchange with other departments and agencies, especially
for foreign investments.
○ Proactively identify and prevent tax evasion through regular monitoring and
data sharing.
● Training and Expertise Development:
○ Organize training programs for tax officials to improve their skills in transfer
pricing and foreign languages.
○ Share experiences and address challenges through conferences and workshops.
○ Actively participate in training initiatives by the General Department of
Taxation.
● Public Awareness and Legal Education:
 ○ Conduct dialogue conferences with businesses to address concerns and solve
problems.
○ Collaborate with business associations and local departments to raise awareness
about transfer pricing regulations.
○ Utilize media channels like radio, TV, and newspapers to educate businesses
about relevant tax laws.

Overall, the document outlines a comprehensive strategy to combat transfer pricing risk in
Vietnam through stricter inspections, improved collaboration, enhanced expertise, and
increased public awareness.

Recipients:

As above;

Deputy TCtr Vu Chi Hung (to report);

Saved: VT,TTKT. (65;2)