Recommended taxpayer actions Taxpayer with operations in Vietnam or that enter into transactions with “associated” parties in Vietnam should review their transfer pricing exposure in Vietnam. Although there are no transfer-pricing-specific penalties in Vietnam, failure to file the required transfer pricing form and to have documentation (including a comparability study when required) may be considered tax avoidance under general tax law provisions. Tax avoidance can trigger penalties of one to three times the amount of the tax adjustment, in addition to interest on the tax adjustment. Taxpayers most at risk are those with recurring losses, particularly exporters, and those that have not complied with the annual reporting and documentation requirements.