The Research On The Control Policies Of Vietnamese Government On The Tax Evasion Via Transfer Pricing Of Multinational Corporation In Vietnam

Under the trend of integrated development of various countries,the opening of the market and the deep integration of the economy have brought many advantages to Vietnam,and also provided Vietnam with many opportunities to attract foreign investors.Especially in the past two years due to the new crown epidemic,Vietnam’s economy has been seriously affected,in order to quickly restore the economy,the Vietnamese government has issued many preferential tax policies for enterprises,especially foreign-funded enterprises and multinational affiliated enterprises.However,Vietnam has therefore had to face the situation that many companies are taking advantage of loopholes in the government’s preferential tax policies to evade taxes.Transfer pricing tax evasion is one of these loopholes.Transfer pricing has become a major issue in the management of the entire country,especially in the management of tax collection.Although the Vietnamese government has taken various measures in recent years,the effect of relevant regulatory policies is not obvious.Under the above background,this paper studies the Vietnamese government’s supervision on transfer pricing tax evasion of transnational affiliated enterprises by combining literature research method,comparative analysis method,case analysis method and countermeasure research method.In the process of research,the author determines that the transfer pricing forms commonly implemented by transnational affiliated enterprises in Vietnam include: Exaggerate the value of registered assets,exaggerate the value of intangible assets,purchase raw materials from affiliated companies at high prices and export at low prices,transfer between branches in different countries,increase advertising costs,etc.At the same time,based on case analysis,it can be seen that the current situation of transfer pricing tax evasion of transnational affiliated enterprises does exist in Vietnam,and its economic consequences are mainly as follows: Base erosion and profit shifting,unhealthy and unfair business environment,inefficient allocation of resources,loss of control over business management and assets of enterprises,increased trade deficits and financial risks.Although Vietnam has made some achievements in the supervision of transfer pricing of multinational enterprises in recent years,there are still shortcomings in legal system,technical facilities and data,correlation and coordination of transfer pricing activities,and management of tax organization structure.In view of the above problems,the author proposes the following solutions to improve the supervision ability of the Vietnamese government on transfer pricing tax evasion based on learning the supervision experience of other countries in the world: We will continue to improve the legal framework of transfer pricing tax evasion behavior regulation,guide the implementation of the determination of transfer price,to set up the transaction price database,database building industry average profit margin,the construction of enterprise information security mechanism,refined,specific regulations,issued by tax authorities to remit advance pricing agreement implementation plan,perfect the tax authorities to architecture,etc.Finally,this paper also puts forward relevant measures from three aspects of system construction,policy implementation and economic environment,so as to reduce the transfer pricing behavior of transnational affiliated enterprises in Vietnam.This paper aims to provide comprehensive suggestions for improvement by comprehensively analyzing the transfer pricing tax evasion of transnational affiliated enterprises in Vietnam and the relevant supervision status of the Vietnamese government,hoping to improve the supervision capacity of the Vietnamese government and play a reference role for other countries or regions.