Audit of Price Transfer Activities in Vietnam


Thi Thu Hoai Pham , Ngoc Ha Tran ,

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Volume 8 - March 2019 (03)


Auditing plays a very important role in ensuring the objective honesty of the financial statements, in addition, the audit also has a role in providing users with information about potential risks. related to the continuous operation of the business. Transfer pricing is a problem that many people care about; transfer prices directly affect the interests of the host country as well as related businesses. Researching the status of price transfer and auditing of transfer pricing activities in our country and some countries in the world, thereby giving appropriate solutions to apply in auditing the transfer pricing activities in Vietnam today


Quality audit, transfer pricing, transfer pricing audit, Vietnam


                        i.            The Ministry of Finance and Circular 17/2005 / TT-BTC provide guidance on the determination of market aging in business transactions between parties with affiliation.

      ii.            The Ministry of Finance, Circular 66/2010 / TT-BTC provides guidance on determining market prices in business transactions between parties with affiliated relationships.

    iii.            Ministry of Finance, Circular No. 201/2013 / TT-BTC regulating transfer pricing method between multinational companies, corporations - APA pre-valuation method (Advance Pricing Arrangement)

     iv.            Deloitte, 2011, Deloitte Global Services Ltd.

       v.            Nguyen Quang Quynh, Nguyen Thi Phuong Hoa, (2012) Curriculum of Auditing Theory, Finance Publishing House, Hanoi.

     vi.            Grant Thornton Japan - Member firm of Grant Thornton International.Ltd

   vii.  , KPMG’s Trensfer Pricing Review

 viii.            The Law on Independent Auditing issued on March 29, 2011.

     ix.            Nguyen Thi Phuong Hoa, Strengthening state control of price transfer activities in enterprises in the context of economic integration in Vietnam, Vietnam Education Publishing House, Hanoi, 2014. [4] General Department statistical

       x.  , Xuan Than - 20% of FDI enterprises transfer prices in 2013, March 23, 2014

     xi.  , October 18, 2013, Many FDI enterprises chose the anti-transfer mechanism of APA

   xii.            General Department of State Taxation (GDT) - Ministry of Finance

 xiii.            Under IRS (The Internal Revenue Service): United States Internal Revenue Service.

 xiv.            Http://

   xv.            Economic Times, August 13, 2014, Transfer pricing and tax evasion: Is there a 'black hand' to help the audit.

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