Uni 19-07-2018 - Guidance on related party file with global corporation

Official letter 48085/CT-TTHT dated 10 July 2018 of Ha Noi Taxation Department guiding related party file for Global group as follows:

Where a taxpayer has a supreme parent company in a foreign country, the taxpayer is responsible for providing a copy of the report on the profits of the supreme parent company in case the supreme parent company of the taxpayer must submit to local tax office.

If the taxpayer fails to provide the final report of the parent company's interstate profits for the tax period corresponding to the tax settlement period of the taxpayer, the taxpayer must provide a report on the profit of the supreme parent company for  the adjacent tax period of the taxpayer and explain the reasons in writing together with the dossier for determining the related party transaction price of taxpayers.

If the taxpayer fails to provide the transnational corporate profits report of the supreme parent company, the taxpayer must provide a written explanation of the reasons, the legal basis and a citation of the specific law of the country. a partner for not allowing a taxpayer to provide a transnational profit report or for the supreme parent company in a partner country not subject to a transnational profit report as required by that country.