Practice area

World TP Reviews

Transfer pricing

Deloitte Vietnam has recently seen the growth of its transfer pricing practice, including transfer pricing audits and APAs. The team has a leading reputation and practice, which is evidenced by its work assisting clients with a huge number of transfer pricing audits. The transfer pricing team works closely with the controversy team in order to offer a streamlined and focused litigation service to the client.


Hoang Thuy Duong and Nhan Huynh, both partners, are the main leaders in the transfer pricing practice. The team consists of more than 60 full time professionals, with six different nationalities. The team has transformed its services into the KPMG integrated international tax practice since, providing professional transfer pricing and integrated tax services for multination corporations and Vietnamese corporations with outbound investments. KPMG works closely with the Vietnamese Ministry of Finance (MOF) and General Department of Taxation (GDT), including the development of the current APA programme and the application of the OECD’s initiatives on BEPS to Vietnam.

In 2017, Hoang Thuy Duong, Huynh Nhan and Ca Nguyen Thuy Nhung assisted one of the largest multinational companies with transfer pricing advisory. The transfer pricing team offered an integrated solution by assessing the implications of various tax, transfer pricing and customs matters on the client’s business model. Elsewhere, Hoang Thy Duong and Tran Thi Thuy Ha helped one of largest manufacturers in the country by providing strategic advice regarding its APA and supporting the client in the pre-filing stage.

The global transfer pricing group has expanded by recruiting a number of transfer pricing professionals with international experience in transfer pricing dispute solution and APAs. For example, Daga Rahul joined in January 2018, bringing with him more than nine years of experience of transfer pricing in India, Bangladesh and now Vietnam.


The PwC transfer pricing team is led by Dean Rolfe and has 42 full time professionals based in both Ho Chi Minh City and Hanoi. The transfer pricing group specialises in APAs and transfer pricing dispute resolutions. It has extensive experience in working with the General Department of Taxation (GDT) APA team. It has also been seen as a leading adviser for clients in several bilateral APA deals. The firm also helps clients deal with disputes with the Vietnamese tax authority.

Christopher Marjoram, Monika Mindszenti and Nguyen Le Nhan Hoa are helping one prominent multinational company on a bilateral APA matter. The team works closely with the GDT to facilitating the lodging of a bilateral APA. Its network offices also participate in the case as advisers to the counterparty in the bilateral APA application.

The group added key professionals in director and senior manage roles recently. This included director Judith Henry and senior manager Pham Hoanh Son, who joined in 2017. James Radford and Khanh Ha Nguyen joined in 2018. The directors and senior managers not only have the extensive experience of European and Asian transfer pricing, but also have a deep expertise and experience in transfer pricing dispute resolution.