BEPS Decree: Addressing Transfer Pricing and Business Structuring

Date(s) - 10/01/2017
8:30 am - 11:00 am

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Park Hyatt Saigon


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Event Description

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.



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


AmCham Members: vnd 550,000| Non-members: vnd 700,000

Reservations/cancellations must be received by 24 hours before the event, and must be made on-line, by email, or by fax. We are unable to accept reservations/cancellations by telephone.


hoang-thuy-duong-kpmgMr. Hoang Thuy Duong, KMPG, Partner

Tax Partner and Head of KPMG’s Integrated International Tax Services in Vietnam.  He has over 16 years of experience in tax planning and structuring for publicly and privately held clients (multi-national and Vietnamese corporations).

Professional and Industry Experience:

—   Duong has been with KPMG for over 16 years, including with KPMG Australia for 15 months in Global Transfer Pricing Services (“GTPS”) and Corporate Tax.

—   Duong is leading KPMG’s GTPS, International Tax, Trade & Customs advisory group in Vietnam.

—   Duong has been in charge of several hundreds of transfer pricing advisory projects.

—   Duong has advised numerous multinationals on tax, customs and transfer pricing planning, compliance and dispute resolution, supply chain tax planning, business restructuring and provided tax due diligence and structuring advice on a number of corporate transactions in various sectors including Industrials (including Automotive), Consumers, Financial Services, Infrastructure, Information Technology, Japanese Market, and a number of other sectors.

—   Duong was the Engagement Partner for a project providing capacity building on transfer pricing and APAs to the Vietnamese tax authority, funded by the European Commission.

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