Abstract
Foreign direct investment (FDI) enterprises are increasingly asserting their important role in Vietnam’s economy. In addition to their contributions, FDI enterprises also cause difficulties in tax administration of the Government, through sophisticated and complicated transfer pricing acts between territories in order to minimize tax obligations. Therefore, the study analyzes the transfer pricing situation at FDI enterprises in Ba Ria - Vung Tau province, the top 10 provinces attracting FDI in Vietnam. The article analyzes the adjustments in the legal framework against transfer pricing activities in Vietnam since 2016 and specific application cases in Ba Ria - Vung Tau province. From there, the article proposes recommendations to strengthen the legal framework against transfer pricing in the future, such as adding transfer pricing issues to relevant Laws, determining tax on turnover, and unifying the principle of determining market prices for associated transactions.
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