Transfer Pricing audit issues

This session aims to provide up-to-date knowledge  about current TP audit trends, commonly seen issues, practical strategies to consider and case studies. The training will be delivered by Transfer Pricing Director of KPMG Vietnam. 

Đọc bản Tiếng Việt


Businesses often face several challenges when dealing with transfer pricing audits. One of the main difficulties is ensuring that their transfer pricing policies comply with the evolving regulations and guidelines. Another challenge is gathering and presenting the required documentation and information to support their transfer pricing decisions. Additionally, businesses may face challenges in effectively communicating their transfer pricing strategies to tax authorities and defending their positions in the event of a dispute.

Coming to the course Transfer Pricing audit issues, participants will understand the legal and technical issues related to the inspection and examination of related transaction prices. This course provides you with the knowledge, processes, methods, skills, and tools needed to conduct an efficient and professional transactional price check and audit.

Key Learning Outcomes

After completing this session you will be able to understand:

1. Common issues raised by the tax authority;

2. Potential TP risk areas

3. TP audit process conducted by different authorities (e.g. provincial level, GDT, State auditor,...);

4. How to prepare/defend pre/during TP audit...

5. Common practices from case studies 

Course Information

    15:00 - 17:00 
    KPMG offices (HCMC & Hanoi)
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I. Overview of TP audit trend in Vietnam

II. TP audit process

III. Potential TP risk areas 

IV. TP risks management pre-TP audit and defense during TP audit.

V.  Practical case studies



Upon successful completion of the course, participants will be awarded a certificate awarded by KPMG.

Becoming certified shows that you have picked up the skills covered in the course and your motivation to learn. You will not only address your business concerns, but also strengthen your own professional development. 

Meet our Speakers

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Ca Nguyen Thuy Nhung
Tax and Legal
KPMG in Vietnam

Nhung has almost 14 years of experience in tax and transfer pricing advisory for publicly and privately held clients (multinational and Vietnamese corporations). 

Nhung specializes in tax and transfer pricing advisory services, particularly in transfer pricing compliance, transfer pricing due diligence, transfer pricing advisory, and transfer pricing dispute resolution and controversy services. Nhung has extensive hands-on experience in representing clients and dealing with local authorities on tax and transfer pricing issues.

Nhung has advised a wide range of Vietnamese and multinational companies from Australia, Europe, the US and the Asia Pacific region in diverse industries including consumer/industrial goods, financial services, electronics, forwarding and logistics, and information technology on tax and transfer pricing matters.

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Ngo Minh Tri
Tax and Legal
KPMG in Vietnam

Tri’s experience includes transfer pricing advisory, APA, and transfer pricing dispute resolution.

With his experience in government liaison, Tri assisted clients in formulating defense strategies and assisting them in defending/negotiating with the tax authorities during tax audits and investigations. 

Tri handled several complex Bilateral APAs in Vietnam and has gained extensive hands-on experience in representing clients as well as dealing with local authorities in APA negotiations with key jurisdictions including Japan, Korea and Singapore. In addition, Tri has established a strong working relationship with the APA team of the General Department of Taxation of Vietnam and was the Engagement Manager of a key client account applying for the first pilot cases of APA in Vietnam.

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Nguyen Trung Thang
Tax and Legal
KPMG in Vietnam

Thang has been with KPMG for over 12 years, advising on International Tax, Transfer Pricing and Trade & Customs matters.

Thang 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, FMCG, Financial Services, Infrastructure, Information Technology, Logistics and a number of other sectors. Thang has been advising many clients including multinational corporations from the US, Europe, Japan, Korea, etc. 


Ms. Nguyen Hoang Anh  


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