This study aims at discovering the relationship between the improvement in the capacity of tax authorities and its effect on the transfer pricing activities of foreign direct investment (FDI) enterprises in four provinces/cities of Vietnam: Ha Noi, Ho Chi Minh, Dong Nai, and Binh Duong province. These are the first localities in Vietnam to establish the Division of Transfer Pricing Inspectorate in local Tax Department, under the direction of General Department of Taxation of Vietnam. The paper then proposes a further study on how the tax authorities of Vietnam should improve their capacities to make FDI enterprises more compliant with the transfer pricing regulations in Vietnam. The authors deploy the method of quantitative research through collecting self-administered closed format questionnaires from people in charge of finance/accounting/transfer pricing of FDI enterprises operating in Ha Noi, Ho Chi Minh, Dong Nai, and Binh Duong province of Vietnam. The findings suggest that there was a strong probability that the capacity of tax authorities would impact on the transfer pricing activities of FDI enterprises in Ha Noi, Ho Chi Minh, Dong Nai, and Binh Duong of Vietnam. Vietnamese Government should enhance the capacity of the tax authorities; establish Transfer Pricing Inspectorate Division in all local Tax Departments of Vietnam. The authors believe that the improvement of tax officials’ capacity especially those in charge of transfer pricing auditing will prevent the FDI enterprises from transfer pricing manipulation, hence these enterprises will be more compliant to transfer pricing regulations of Vietnam. The most significant value of the study is to support Vietnamese policymakers, especially those in the field of Finance (Ministry of Finance, General Department of Taxation) to improve their capacity when carrying out transfer pricing audit in FDI enterprises. The more transparent and aggressive the tax officials are, the better these enterprises follow the regulations.

The purpose of this paper is to evaluate the differentials effects of the tax rate on transfer pricing activities in foreign direct investment enterprises in Vietnam. The study then suggests further research on the determinants over transfer pricing activities of these enterprises to have better solutions in dealing with transfer mispricing in Vietnam. A quantitative research method involving self-administered closed-ended questionnaires were extended to Managing Directors/Chief Executive Officers, Tax Managers/ Directors, Chief Finance Officers or Heads of Finance from foreign direct investment enterprises in Vietnam. Findings indicate a strong relationship between corporate tax rate differentials and the transfer pricing activities in foreign direct investment enterprises in Vietnam. The findings support Vietnamese policymakers, academic researchers, auditors, investors to have further study on the effect of the tax rate on transfer pricing activities of the enterprises. Nevertheless, tax officials and accounting representatives can have in-depth knowledge with regards to transfer pricing activities which the outcome of this study aspires as guidance for better understanding the aspects of transfer pricing while doing business in Vietnam.

The purpose of this paper is to understand how transfer pricing law affects transfer pricing decision making in foreign direct investment enterprises in Vietnam. The study also suggests further research on the determinants over transfer pricing decision making of these enterprises to have better solutions to deal with transfer mispricing in Vietnam. A quantitative research method involving self-administered closed ended questionnaires is extended to manage Directors/Chief Executive Officers, Tax Managers/ Directors, Chief Finance Officers or Heads of Finance from foreign direct investment enterprises in Vietnam. Findings indicate a strong probability of a relationship between transfer pricing law and the transfer pricing decision making of foreign direct investment enterprises in Vietnam. Therefore, there is a need for government to have specific law on transfer pricing. Good transfer pricing database is al-so expected; punishment should be reasonable; transfer pricing audit process should be stronger; transfer pricing trainings should be introduced more to the enterprises. It is be-lieved that the implementation of suitable transfer pricing law in Vietnam will assist the government better deal with transfer pricing abuse in foreign direct investment enterprises. The findings support Vietnamese policy makers to improve the law on transfer pricing. Nevertheless, tax officials and accounting representatives can have indepth knowledge with regard to transfer pricing decision making which the outcome of this study aspires as guidance for better understanding the aspects of transfer pricing decision making while doing business in Vietnam.