Corporate tax treatment of transfer pricing

In this profound article the author describes the Vietnamese tax environment for MNEs operating in Vietnam. Perceived abusive situations, such as that more than two thirds of the Vietnamese companies of MNES have been sustaining losses for many years; foreign exchange control considerations; and concerns about the negative effects of actions too harsh, were the basis for the government to introduce transfer pricing legislation during the last years. In this article the legislation is set out and discussed.