THE TRANSFER PRICING FILES

THE TRANSFER PRICING FILES

Pursuant to Clause 4, Article 18 of Decree 132/2020/ND-CP, the transfer pricing files comprising information, documents, data and records, including:

1. Interrelationship and related party transaction information provided in the form given in Appendix I hereto Appendix I.pdf 

2. Local files, including information about transfer pricing, transfer pricing policies and methods, prepared and deposited at taxpayers’ offices according to the directory of information and documents prescribed in Appendix II hereto Appendix II.pdf 

3. Master files containing information about business activities of multinational groups, transfer pricing policies and methods of global groups and policies on allocation of income and decentralization of operations and functions in value chains of groups according to the directory of information and documents prescribed in Appendix III hereto Appendix III.pdf 

4. Country-by-Country reports of profits of ultimate parent companies prescribed in clause 5 of this Article and Appendix IV hereto Appendix IV.pdf