02 Subjects Applicable to APA in Circular 201/2013/TT-BTC

18:09, 10/07/2024

Recently, Circular 201/2013/TT-BTC was issued by the Minister of Finance, providing guidelines on the application of the Advance Pricing Agreement (APA) method for tax management.

The subjects to which APA applies in Circular 201/2013/TT-BTC include:

Subjects to which APA applies, Circular 201/2013/TT-BTC

Source: Internet

- Organizations and units with affiliated relationships within an enterprise or economic group operating in different localities (including countries and territories);- Organizations and units having a relationship as a permanent establishment and the head office of the enterprise. In this case, each permanent establishment will be considered a separate and completely independent enterprise (taxpayer) from the head office or other permanent establishments of the enterprise.

In addition, Circular 201 also stipulates two forms of APA as follows:

- Unilateral APA is an APA negotiated and signed between the Vietnamese tax authority and the taxpayer applying for the APA.- Bilateral or multilateral APA is an APA negotiated and signed between the Vietnamese tax authority, the taxpayer, and one or more partner tax authorities related to determining the tax obligations of the taxpayer applying for the APA based on a Tax Agreement.

See additional provisions in Circular 201/2013/TT-BTC effective from February 5, 2014.

Thu Ba

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