Whether you need someone to run your tax filings every month or a defensible answer on a single transaction, the goal is the same: tax positions that hold up when the tax authority looks at them. Most FDI companies need both, ongoing compliance and advice before the decisions that carry risk.
Background
FDI subsidiaries regularly face transactions their in-house accountant rarely sees: royalties paid to the parent, technical services received from abroad, management costs allocated within the group, or profits repatriated to shareholders.
Each of these engages a distinct set of rules, whether foreign contractor tax, transfer pricing documentation or the conditions attached to profit remittance. Getting it wrong is not immediately visible. It typically surfaces during an inspection several years later, by which time the assessed amount has compounded.
The cost of an opinion before a transaction is almost always lower than the cost of remediating it afterwards, both in money and in time spent explaining.
Common challenges
- Applying habit rather than rules. Treating a new transaction the way a previous, materially different one was treated is a common source of error.
- Foreign contractor tax missed. Payments to overseas suppliers made without withholding, discovered at inspection together with accumulated interest.
- Transfer pricing documentation not prepared. Dealings with the parent and group companies can trigger declaration and documentation obligations. Missing them exposes the company to a determined price.
- Profit repatriated at the wrong time. Remittance is subject to conditions and timing. Getting the sequence wrong means the bank declines the transfer or the position is challenged later.
- Advice without a documented basis. An informal answer with no legal reference is of no help when the company has to explain itself to the tax authority.
How TrustlineAX helps
- Transfer pricing position assessed. Identification of related parties, declaration and documentation obligations, and an assessment of the risk in your current intercompany pricing.
- Foreign contractor tax determined. Which payments fall within scope, the calculation method and rate, the withholding obligation and the filing mechanics.
- Profit and capital repatriation planned. Conditions reviewed, the permissible timing established, documentation prepared and the transfer routed correctly.
- Tax incentives verified. Whether the company qualifies, what must be maintained to keep the benefit, and the exposure if conditions are not met.
- Options rather than a single answer. For each situation we set out the workable positions with their respective risk, so the decision remains a commercial one made with full information.
- Written opinions when you need them. Formal written advice where you need something for the file or for your parent company.
When companies call us
Before signing a contract
Who bears the tax, which invoices are needed, and how the payment should be structured.
Paying suppliers abroad
Foreign contractor tax, double tax treaties and the documents needed to apply them.
Related-party transactions
Intercompany pricing, management fees and the transfer pricing file behind them.
Tax incentives
Whether your project qualifies, and how to keep the incentive once you have it.
Tax audits and inspections
Preparation, explanations to the authority and support until the final conclusion.
Restructuring
Capital changes, transfers and closures planned with the tax impact in view.
Scope of service
Ongoing tax compliance is delivered as fixed items, confirmed in a written proposal. Advisory work on a specific transaction is quoted per matter.
B · Tax compliance
VAT returns
Quarterly / Monthly
- Prepare the VAT declaration and send it for your approval.
- File it and confirm the amount payable and the deadline.
Quarterly filing applies where prior-year revenue is VND 50 billion or less; above that, filing is monthly.
Foreign contractor tax (FCT)
Per payment
- Prepare a withholding declaration for each payment made overseas.
- File after your approval and confirm the amount payable.
Corporate income tax finalisation
Annual
- Prepare the annual CIT return and review taxable revenue and deductible expenses.
- Issue a letter setting out the issues found, the risk attached to each and the options open to you.
- File the approved return and advise on quarterly provisional payments.
Related-party transaction disclosure
Annual
- Identify related-party transactions and complete the disclosure filed with the CIT return.
- Respond to tax authority queries on the disclosures.
Not included — the transfer pricing documentation file and defence of your pricing policy, available under a separate scope.
Advisory · quoted per matter
Transfer pricing documentation
Per year
- Related-party mapping, pricing method and the documentation file required by the transfer pricing rules.
Foreign contractor tax review
Per matter
- Review of contracts with overseas suppliers: scope, method, rate and withholding mechanics.
Profit repatriation and tax incentives
Per matter
- Conditions and timing for remitting profit; eligibility for and retention of tax incentives.
Tax inspection support
Per matter
- Pre-inspection review, document preparation and representation before the tax authority. Quoted before we take it on.
Written opinions and rulings
Per matter
- Formal written advice, and written queries to the tax authority drafted and followed through to response.
How fees work
- Every engagement starts with a written proposal: scope agreed item by item, fees fixed per item, valid for 30 days.
- Nothing outside the agreed scope is charged without your prior written agreement.
- Fees exclude VAT and out-of-pocket costs such as notarisation, legalisation and certified translation.
Who we work with
- FDI subsidiaries with royalties, service fees or management charges paid to the parent company.
- Companies with expatriate staff whose personal income tax position needs to be right from the start.
- Finance teams preparing for a tax inspection or closing an inspection already under way.
- Investors planning to repatriate profit or restructure who need a documented basis before acting.
How we work
- Question intake. We establish the substance of the transaction, the parties and what you are trying to achieve.
- Document review. Contracts and records examined so the advice reflects the actual arrangement.
- Analysis. Applicable rules identified, together with how the tax authority typically approaches this transaction type.
- Opinion delivered. Options set out with risk and legal basis for each.
- Implementation support. Assistance with documentation, filings or dealings with the authorities if required.
Options, not just one answer
Where the law leaves room for judgement, we set out the realistic options side by side so the decision stays a commercial one made with full information.
| Illustration | Approach | Tax risk | Effort |
|---|---|---|---|
| Option A | Most conservative treatment | ● Low | Higher tax cost |
| Option B | Balanced, well-documented position | ● Medium | More documentation |
| Option C | Most tax-efficient position | ● Higher | Strong evidence needed |
Tax audit support, start to finish
Frequently asked questions
How are your fees structured?
Ongoing tax compliance is billed as a fixed monthly fee based on your filing cycle and volume. For a clearly bounded advisory question we quote a fixed fee for the matter; where substantial document review is needed, we quote after a preliminary assessment.
Will you advise on a single transaction?
Yes. You do not need an ongoing engagement to obtain a technical opinion on one situation.
Does a written opinion protect us with the tax authority?
An adviser’s opinion does not substitute for official guidance from the tax authority. That said, a file containing documented analysis and legal reasoning puts you in a substantially stronger position than having nothing on record.
Can we obtain a ruling from the tax authority?
Yes. For unclear or high value matters a company can submit a written query to the tax authority. We draft the submission and follow it through to response.
Related services
TrustlineAX is a private advisory firm and is not affiliated with any government agency. Official fees and taxes are paid directly to the competent authorities. An adviser opinion does not substitute for official guidance from the tax authority. This page is general information, not tax or legal advice for your specific case.