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.

This study aims to analyze the influence of tax expense, bonus mechanism, and incentive tunneling on transfer pricing with profitability as moderating. The population is mining companies listed on the Indonesia Stock Exchange in 2016-2019. The sample selection used a purposive sampling technique and obtained 45 analysis units. Data analysis method used moderated regression analysis (MRA). The study showed that tunneling incentive had a significant positive on transfer pricing decision. Tax expense and bonus mechanism had no significant effect on transfer pricing decisions. Profitability strengthened the effect of tax expense on transfer pricing decisions. However, profitability was unable to moderate the influence of bonus mechanism and tunneling incentive towards on transfer pricing decisions. The conclusions are that shareholders the majority of a controlled by the foreign shown to improve the transfer pricing decision. An increase in profitability followed the transfer pricing decision high to reduce tax expense in the company.

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.