Transfer Pricing
Compliance – Optimization – Sustainability
Services
General Description of the Service
Through our Transfer Pricing Advisory Services, our professionals help enterprises ensure compliance with transfer pricing regulations and optimise related-party transactions in accordance with prevailing legal requirements. Our services include the preparation of transfer pricing documentation, pre-audit tax compliance reviews, and support in responding to requests from the tax authorities during transfer pricing audits.
Service deliverables include transfer pricing documentation comprising the Local File, Master File and Country-by-Country Report (CbCR), as well as review reports setting out transfer pricing-related tax findings, risks and recommendations. In addition, Crowe Vietnam supports clients in preparing for tax audits, helping them strengthen their ability to respond to requests from the tax authorities and minimise additional tax costs that may arise.
Service Context
Enterprises typically require Transfer Pricing Advisory Services in the following circumstances:
- Engaging in transactions with parent companies, subsidiaries or related parties in Vietnam or overseas, including purchases and sales of goods and services, financing arrangements, or transfers of intangible assets.
- Preparing transfer pricing documentation to comply with Decree No. 132/2020/ND-CP, OECD guidelines or group requirements.
- Before or during a tax audit, when a compliance review and support in responding to requests from the tax authorities are required.
- When restructuring the business, expanding investments or changing the business model, where transfer pricing risks need to be assessed and an appropriate pricing method determined.
- When seeking to optimise tax obligations and manage long-term risks, particularly for FDI enterprises or businesses operating across multiple jurisdictions.
Service delivery process and timeline
Service process
- Conduct detailed discussions with the client to agree on the scope of work, cooperation approach, required documentation and responsibilities of each party.
- Collect an overview of the client’s business operations.
- Prepare a list of documents and information to be provided by the client.
- Collect data at the client’s premises and interview key personnel.
- Perform industry, functional, risk and financial analyses.
- Apply appropriate transfer pricing methods, including comparable price, cost-based and profit allocation methods.
- Analyse related-party transactions and benchmark them against comparable transactions.
- Review documentation and related-party transactions to assess compliance with transfer pricing regulations.
- Analyse potential risks and recommend solutions to mitigate tax exposure.
- Advise the client on transfer pricing audit processes and procedures.
- Assist the client in preparing explanation letters and response strategies for the tax authorities.
- Monitor and follow up on the status of the audit and recommend subsequent actions.
- Assist in addressing tax audit minutes and advise on any additional tax payments, where applicable.
- Present the analysis results and recommended solutions to the client via email or in-person meetings.
- Discuss and agree on the next steps.
- Provide the draft report to the client for review and confirmation.
- Issue the final report to the client and, where applicable, the tax authorities.
Timeline for service delivery
The timeline for our Transfer Pricing Advisory Services depends significantly on the scope of work, the client’s responsiveness and level of cooperation, as well as the involvement of relevant parties such as the Board of Directors, relevant functional departments and the tax authorities.
In most cases, we typically complete the service within 5 to 6 weeks. However, where an accelerated timeline is required, we may apply specific measures such as allocating additional resources, adjusting our processes and procedures to provide greater flexibility, and requesting close and timely cooperation from the client to ensure both the required timeline and quality of work are achieved.
Quotation process and service fees
To prepare and send you a tailored quotation, we kindly request that you provide relevant information via our form and/or through an in-depth discussion. Based on the information collected, we will analyze your needs and specific requirements in order to:
- Assess the feasibility of service delivery: Determine whether we can provide the requested service appropriately and at a guaranteed quality level.
- Advise on optimal solutions: Recommend alternative solutions (if any) to help optimize efficiency and cost-effectiveness for your organization.
If we are able to support you, we will propose a reasonable fee based on:
- An estimated workload of the engagement;
- The level of professional expertise required from our team.
Estimated response time: The quotation process will be completed within 12 to 24 hours upon receiving your request.
Global minimum tax advisory services
Support enterprises in assessing the impact of GMT through reviews of the group structure, analysis of the effective tax rate (ETR), identification of potential top-up tax liabilities, and advisory on solutions to optimise investment structures, tax incentives and value chains.
Service deliverables include: a GMT impact assessment report, top-up tax calculation and forecasting model, tax risk analysis report and compliance recommendations; together with support in data standardisation, preparation of required documentation and reports, training, and policy updates.
Frequently asked questions
1. Does this service ensure information confidentiality?
When providing transfer pricing services, we are committed to maintaining the absolute confidentiality of all your financial and tax information, in full compliance with data protection regulations.
2. Can Crowe Vietnam’s services be customized to fit the needs or scale of a business?
Yes, we design our services to be flexible and tailored to businesses of all sizes from FDI start-ups to multinational corporations ensuring the level of support, cost, and scope of advisory are aligned with each client’s specific needs.
3. Which steps can Crowe Vietnam support during tax audits or Advance Pricing Agreement (APA) negotiations?
Crowe Vietnam provides comprehensive support ranging from compliance review prior to tax audits, documentation preparation, and direct responses to tax authorities, to advisory and negotiation on Advance Pricing Agreements (APAs). We help businesses minimize risks, effectively resolve disputes, and develop long-term transfer pricing strategies.
4. Does Crowe Vietnam have experience in providing transfer pricing advisory for specific industries such as manufacturing, trading, or services?
We have successfully implemented numerous transfer pricing advisory projects for businesses across manufacturing, trading, distribution, services, and FDI sectors. With in-depth industry knowledge and international practices, we deliver tailored solutions aligned with each client’s business operations.
5. Compared to managing transfer pricing internally, what are the cost and risk management benefits of engaging Crowe Vietnam?
Engaging Crowe Vietnam helps businesses save time, minimize costs arising from errors, and manage risks effectively through our team of experts well-versed in both Vietnamese regulations and international standards. We also provide objective perspectives, strategic insights, and extensive experience in handling complex situations that in-house teams may lack the resources or expertise to address.
Brand commitment
Crowe Vietnam is committed to building and delivering on its brand personality, with the goal of fostering trust and providing an exceptional experience throughout our journey with clients and partners.
High professional quality at a reasonable cost
Crowe Vietnam is committed to delivering high quality solutions and services at reasonable costs, ensuring an exceptional client experience. We consistently strive for differentiation and continuously enhance the professional capabilities of our team to best meet the evolving needs of our clients.
Client and Partner Profiles
We aspire to collaborate with clients and partners who are committed to:
Insights
News
Overview of Crowe Vietnam
Top 9
International brand in Audit, Accounting, Tax, and Business Advisory
Top 9
Audit service provider for FDI enterprises in Vietnam
Top 15
Audit and Advisory service providers in Vietnam
18+
Years of operation (since 2008)
180+
Personnel (350+ including personnel of Crowe’s business associates
in Vietnam)
in Vietnam)
4
Offices
1000+
Clients (1500+ including clients of Crowe’s business associates in Vietnam)
Overview video of Crowe Vietnam
Why choose us for this service?
Choosing the right service partner is a key factor in ensuring both effectiveness and peace of mind. Here’s why Crowe Vietnam is the trusted choice for you.
International Brand
Crowe Vietnam is a full member of Crowe Global, a top 10 global network of audit, accounting, tax and advisory firms operating in 150 countries. Our international brand enables us to deliver high-quality audit services in accordance with international standards, helping clients enhance their credibility in the marketplace.
Assured Expertise
With a team of experienced professionals holding internationally recognised qualifications such as ACCA, CPA, ICAEW and CA ANZ, Crowe Vietnam is committed to delivering audit and assurance services of high professional quality, fully aligned with both international and Vietnamese auditing standards.
Professional Services
Our audit clients regularly receive useful newsletters and publications, have opportunities to participate in professional seminars with experienced specialists, and gain access to a range of modern and practical support tools developed and continuously enhanced by Crowe Vietnam.
Strict Confidentiality
We place the highest priority on confidentiality and compliance, applying rigorous control measures to protect client information and prevent data security risks, thereby ensuring maximum transparency and security throughout the audit engagement.
Global Support
Through our extensive connection with the Crowe Global network, Crowe Vietnam is always ready to help clients access international professionals and seconded personnel, providing comprehensive advisory and support to address complex issues in today’s global business environment.
Reasonable Fees
Crowe Vietnam is committed to delivering high-quality audit solutions at reasonable fees, helping clients optimise costs. We continuously strive to improve and enhance operational efficiency, enabling clients to achieve maximum value within an appropriate budget.
Senior Personnel
Nam Nguyen
Chairman & Managing PartnerFCPA, CTA, FCCA
Lam Vu
General Director & Audit DirectorCPA VN, CPA AU, CTA, MA
Linh Nguyen
Partner, Tax & AdvisoryCPA VN, CPA Aust., CTA
Phat Tran
Partner, Audit & AssuranceFCCA, CIA, CPA VN, CTA