The tax authority began to scrutinize transfer pricing much more closely following the release of Circular 66. Multinationalcompanies that incur persistent losses in Vietnam and yet continue to expand operations there can expect particular scrutiny.It is also understood that given the increasing foreign investment in manufacturing, this sector will be particularly targeted fortransfer pricing scrutiny and the initial focus has been on the automotive, garments/textile and electronics sectors. Recently,this has expanded to the real estate and construction sectors.The burden of proof rests with the taxpayer to prove that the figures stated in the tax return declarations (or in documentssupporting transfer prices for that matter) are proper and reasonable.
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