04Practice area

Tax & Accounting.

Tax & accounting. Tax advisory for FDI and Vietnamese companies — including international tax structuring, transfer pricing and representation in tax audits.

Practice lead: Nguyễn Hồng Ngọc
Senior Associate · Hanoi
Team size: 2 lawyers · 3 associates
Languages: VI · EN

01 — Scope of work

What we do.

Updated Jun 2026

Corporate tax in Vietnam is changing rapidly — particularly for FDI enterprises affected by the global minimum tax under OECD Pillar Two and new transfer pricing regulations.

BLF approaches tax from a legal perspective: we do not merely calculate tax liabilities but assess the risk of disputes with the tax authorities, particularly in transactions involving asset valuation, profit transfers and VAT refunds.

Scope of work

Tax planning for FDI enterprises: Advising on optimal tax structure for FDI projects — including CIT, tax incentives and a compliance roadmap.
Transfer pricing advisory: Building arm's-length documentation under Decree 132/2020 and defending against transfer pricing audits.
Double tax treaty applications: Applying DTTs for foreign enterprises with Vietnamese-source income — applying withholding tax exemptions and reductions.
VAT refunds & withholding tax: Supporting VAT refund applications for exporters and representing clients in refund verification reviews.
Tax audit & inspection representation: Preparing documentation and representing companies before tax authorities — including appeals against penalty decisions.
Accounting support for start-up phase: Advising on accounting method selection and establishing initial accounting systems for newly incorporated companies.

02 — Common engagements

Three typical transaction types.

Anonymized

Use case · FDI tax

Global minimum tax advisory for a manufacturing group.

A Japanese manufacturing group with global revenue over EUR 750 million needed an assessment of OECD Pillar Two impact. BLF analysed top-up tax obligations in Vietnam and advised on optimal structuring.

OutcomeTax analysis · 3 structure scenarios

Use case · Transfer pricing

Defending a transfer pricing file during audit.

An FDI electronics company was investigated by the tax authority for transfer pricing on related-party transactions exceeding VND 200 billion. BLF prepared arm's-length documentation and successfully represented the company throughout the audit.

OutcomeAudit closed · no back-assessment

Use case · VAT refund

VAT refund recovery for an export enterprise.

An aquaculture exporter had a VAT refund balance of VND 12 billion delayed for 18 months. BLF drafted a formal complaint and coordinated with the local tax authority to expedite the refund process.

RecoveredVND 12 billion · 60 days after complaint

03 — Lead lawyer